Pennsylvania State Police Sergeant David Holt II filed suit against the Commonwealth of Pennsylvania and four of his supervisors. Holt alleged multiple instances of race discrimination and retaliation in violation of Title VII of the Pennsylvania Human Relations Act, and contrary to the guarantees of the Equal Protection Clause and the First Amendment.
A jury returned a partial verdict, thereby necessitating a second trial. Holt prevailed on several of his claims, receiving an award of $1.9 million. After the trial, the State successfully moved for judgment as a matter of law on all but one of the claims and ordered the damages reduced to $50,000 through what is known as a remittitur.
Holt appealed and succeeded in having the verdict in his favor on one of the claims reinstated, subject to the remittitur, which had not been appealed. On remand, Holt elected to have a new trial on damages instead of accepting the $50,000 on the remittitur. This time, a jury awarded Holt only $2,700. Holt again appealed.
Holt argued that the $2,700 jury award was against the weight of the evidence and was unreasonable as a matter of law. The federal Third Circuit Court of Appeals disagreed.
The Court found that “a jury verdict may be overturned on the basis that it is against the weight of the evidence only when the record shows that the jury’s verdict resulted in a miscarriage of justice or where the verdict, on the record, cries out to be overturned or shocks the conscience. While Holt is disappointed with the jury’s award – perhaps even personally shocked – the record fails to establish that there was a miscarriage of justice, nor does it cry out for the verdict to be overturned.
“The jury was properly instructed that it could address both the intangible aspects of harm that Holt sustained, such as Holt’s mental anguish, his pain and suffering, as well as his actual monetary loss. There is no basis for concluding that the verdict is against the weight of the evidence.”
Holt v. Commonwealth of Pennsylvania, 2019 WL 3021798 (3d Cir. 2019)