Joe Morgan v. Bill Woessner, and Clay Searle Los Angeles City, (Two Cases)

I. OVERVIEW

Joe Morgan, an ex-professional baseball player, brought a Section 1983 suit against federal agent Bill Woessner, Los Angeles police officer Clay Searle, and the City of Los Angeles for harm associated with an incident at Los Angeles International Airport (LAX) in March of 1988. At the first trial, the jury found that Morgan had not been unlawfully detained. The district court, however, granted Morgan’s motion for a judgment notwithstanding the verdict (JNOV) and a new trial because it found that Searle’s stop of Morgan was unconstitutional as a matter of law.

At the second trial, the district court instructed the jury that the initial contact between Morgan and Searle was unconstitutional, and instructed it to determine only whether Morgan’s subsequent arrest was lawful and whether Morgan suffered harm in connection with any unconstitutional conduct, and to consider Morgan’s state law claims of false imprisonment, battery, and intentional infliction of emotional distress. The jury found for Morgan on all of these issues, and awarded Morgan a total of $90,000 in compensatory damages and another $450,000 in punitive damages. Searle and the City of Los Angeles appeal.…