Czajka v. Black

Czajka v. Black, 901 F.2d 1484 (8th Cir. 1990) · United States Court of Appeals for the Eighth Circuit · May 2, 1990

Summary

Prisoners' § 1983 action alleging Eighth and Fourteenth Amendment violations during a prison disturbance. Eighth Circuit affirmed denial of new trial, holding that a motion for new trial based on weight of evidence is "virtually unassailable" and reviewed only for clear abuse of discretion. Court also rejected claim of excessive judicial intervention, finding no bias or partiality in judge's questioning or comments. Key topics: Section 1983, prison conditions, new trial standard, abuse of discretion, judicial intervention.

Holdings

  1. The district court did not abuse its discretion in denying the motion for new trial; the denial is virtually unassailable on appeal and reviewed only for a clear abuse of discretion.
  2. The district court did not display bias, advocacy, or partiality, and thus committed no error.

Questions Presented

  1. Whether the district court abused its discretion in denying the motion for new trial on the ground that the jury's verdict was against the weight of the evidence
  2. Whether the district court committed plain error by excessively intervening in the trial, thereby prejudicing appellants' right to a fair trial

Disposition

affirmed

Cases Cited (13)

  • McDonough Power Equip. v. Greenwood, 464 U.S. 548, 556 (1984)(cited)
  • Green v. American Airlines, 804 F.2d 453, 455 (8th Cir. 1986)(cited)
  • Kelley v. Crunk, 713 F.2d 426, 427 (8th Cir. 1983) (per curiam)(cited)
  • Daley v. Webb, 885 F.2d 486, 489 (8th Cir. 1989)(cited)
  • Browning-Ferris Indus. v. Kelco Disposal, 109 S.Ct. 2909, 2922 n.25 (1989)(cited)
  • Crowley Bev. Co. v. Miller Brewing Co., 862 F.2d 688, 690 (8th Cir. 1988)(cited)
  • Grogg v. Missouri Pac. R.R., 841 F.2d 210, 214 (8th Cir. 1988)(cited)
  • Jones v. Wal-Mart Stores, 870 F.2d 982, 986 (5th Cir. 1989)(distinguished)
  • Franks v. Associated Air Center, 663 F.2d 583, 591-92 (5th Cir. 1981) (per curiam)(distinguished)
  • McKinzie v. Fleming, 588 F.2d 165, 167 (5th Cir. 1979) (per curiam)(distinguished)

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