Watson v. City of San Jose

A higher court will reverse a district court’s order under an abuse of discretion standard only when the district court reaches a result that is implausible, illogical, or there is no inferential support that may be gleaned from the record.

Tracy Watson and Renee Stalker (the Stalkers), are married and have three children who the court refers to by their first initial: O, S, and R. O’s teacher suspected O might be sexually abused at home and reported it to the Santa Clara County Department of Family and Children’s Services. After a social worker’s multiple failed attempts to meet with the family, the police visited the Stalker’s home. O was not there and Mr. Stalker refused to bring O to the house to be interviewed. In response, the officers removed S and R from the home. The Stalkers filed a civil lawsuit against the city of San Jose in federal court under 42 U.S.C. § 1983 claiming the police conducted a warrantless seizure of their children. The Stalker’s were awarded $3,250,000 in damages. The district court granted the city’s motion for a new trial to re-assess the damages. The district court held that the award was “beyond the realm of reasonableness” emphasizing that R received $250,000 in compensatory damages even though the Plaintiffs did not introduce any evidence that R experienced distress from the seizure. The new trial’s jury awarded the family a total of $210,002 of compensatory damages. On appeal, the Ninth Circuit considers whether the district court’s order granting a new trial was an abuse of discretion. The panel will reverse a district court’s order under an abuse of discretion standard only when the district court reaches a result that is “illogical, implausible, or without support in the inferences that may be drawn from the record.” The panel held that the order was not an abuse of discretion and affirmed the judgment entered by the district court awarding the Stalker’s a new, more reasonable total of $210,002 in damages. AFFIRMED.