Hygh v. Jacobs case brief

Hygh v. Jacobs case brief

961 F.2d 359, 1992 U.S. App.

CASE SYNOPSIS: Defendant police officer sought review of a decision from the United States District Court for the Northern District of New York, which rendered judgment in favor of plaintiff claimant, in plaintiff's action for damages pursuant to 42 U.S.C.S. § 1983 (1988), based on allegations of false arrest, excessive use of force, and malicious prosecution. Plaintiff cross-appealed the award of nominal damages on the malicious prosecution claim.

FACTS: Plaintiff claimant filed an action for damages against defendants, police officer, municipality, and individuals, pursuant to 42 U.S.C.S. § 1983, after plaintiff was injured during an arrest. The trial court rendered judgment for plaintiff, and defendant officer sought review. On appeal, the court affirmed in part and reversed in part.

ANALYSIS:

The court affirmed the judgment as to defendant's excessive use of force; although the trial court had erred in admitting conclusory expert testimony on the issue, the court held the error was not reversible because the evidence supported the finding and proper jury instructions were given. The court vacated the false arrest damage award, finding that the award was inconsistent with substantial justice because evidence concerning events following plaintiff's arraignment, testimony by plaintiff concerning his pain and suffering, and a mugshot of plaintiff depicting his facial injuries were all inadmissible. The court also reversed the malicious prosecution judgment because, as a matter of law, a dismissal in the interest of justice was not a termination in plaintiff's favor and therefore an essential element of the claim was not established.

CONCLUSION: The court affirmed the excessive use of force judgment in favor of plaintiff claimant because the trial court's error in admitting conclusory expert testimony was negated by jury instructions and the evidence supported the judgment. The court vacated and remanded plaintiff's false arrest judgment because prejudicial evidence was erroneously admitted, and reversed plaintiff's malicious prosecution claim, because it was legally not proven.

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