Kelly Fuery v. City of Chicago

Summary

The Seventh Circuit affirmed the district court's exercise of its inherent authority to set aside a jury verdict and enter judgment for defendants as a sanction for the plaintiffs' and their attorney's pervasive bad faith misconduct during trial, including repeated violations of motions in limine, witness coaching, dishonesty to the court, and destruction of evidence. The court held that the district court did not abuse its discretion in finding that the continuous, contumacious conduct warranted the severe sanction, and that the plaintiffs received adequate due process through warnings and evidentiary hearings. The opinion also addresses the calibration of sanctions under *Goodyear Tire & Rubber Co. v. Haeger*, concluding that the entry of judgment was a reasonable exercise of discretion even if the compensatory principle applied.

Holdings

1. The district court did not abuse its discretion. The court made thorough findings of bad faith conduct by the plaintiffs and their counsel, considered the egregiousness of the conduct, the effect on the trial, and the possibility of lesser sanctions, and the sanction of entering judgment for defendants was appropriate to maintain the integrity of the trial process.

Questions Presented

1. Whether the district court abused its discretion in using its inherent authority to enter judgment in favor of the defendants as a sanction for the plaintiffs' bad faith conduct, including whether the court's findings of bad faith were supported, whether the sanction was proportionate, and whether the plaintiffs received adequate due process.

Disposition

affirmed