United States District Court, D. Arizona
STEPHEN M. McNAMEE, Senior District Judge.
The Court is in the midst of conducting a jury trial in this matter. Plaintiffs have now rested their case and Defendants move under Fed.R.Civ.P. 50(a) for judgment as a matter of law. (Doc. 217.) The parties presented cogent and thorough arguments regarding this motion, which the Court took under advisement. The Court now grants, in part, and denies, in part, Defendants' motion.
STANDARD OF REVIEW
Rule 50(a) reads in full: "If a party has been fully heard on an issue during a jury trial and the court finds that a reasonable jury would not have a legally sufficient basis to find for the party on that issue, the court may resolve the issue against the party..." Fed.R.Civ.P. 50(a)(1)(A) (West 2014). In analyzing a motion for judgment as a matter of law, the Court must draw all reasonable inferences in favor of the nonmoving party without making credibility assessments or weighing the evidence. See, e.g., Summers v. Delta Air Lines, Inc., 508 F.3d 923 (9th Cir. 2007). However, the nonmoving party is not entitled to the benefit of unreasonable inferences, or those that are contrary to the undisputed facts. See id.
I. 42 U.S.C. § 1983 Excessive Force
Extent of Plaintiffs' Physical Injuries
Defendants argue that Plaintiffs' excessive force claims should be denied as a matter of law because Plaintiffs failed to prove that they suffered significant injuries, thus failing to demonstrate that excessive force was used. (Doc. 217 at 7.). The Court disagrees.
In Hudson v. McMillian, 503 U.S. 1 (1992), the Supreme Court rejected the notion that "significant injury" is a threshold requirement for stating an excessive force claim. The "core judicial inquiry, " it held, was not whether a certain quantum of injury was sustained, but rather "whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm." Id.; accord Wilkins v. Gaddy, 559 U.S. 34, 37 (2010). In the seminal case Whitley v. Albers, 475 U.S. 312, 320-21, (1986), the Supreme Court established five factors that courts must consider when determining "good faith effort" in the prisoner context:
(1) the need for the application of force,
(2) the relationship between the need and the amount of force that was used
(3) the extent of injury inflicted
(4) the extent of the threat to the safety of staff and inmates, as reasonably perceived by the responsible officials on the ...