Bento v. Letourneau

United States District Court for the District of Rhode Island · February 27, 2025 · No. 1:20-cv-00444

Summary

This federal district court order denies a plaintiff's motion for a new trial regarding her Fourteenth Amendment equal protection claim against a police officer and the City of Pawtucket. The court held that the jury's verdict for the defendants was supported by credible testimony and that conflicting accounts regarding racial animus and adverse action are proper matters for jury determination. Consequently, the judge found no grounds to override the verdict under Federal Rule of Civil Procedure 59(a).

Court
United States District Court for the District of Rhode Island
Writing for the Court
Mary S. McElroy
Jurisdiction
United States District Court for the District of Rhode Island
Decision date
February 27, 2025
Docket number
1:20-cv-00444
Procedural posture
Plaintiff moved for a new trial under Fed. R. Civ. P. 59(a); motion denied.
Standard of review
abuse of discretion
Precedential value
nonprecedential
Parties
Cristina M. Bento v. Craig Letourneau, City of Pawtucket
Disposition
other

Topics

civil rightsequal protectionfourteenth amendmentcivil procedure

Practice areas

civil rightscivil procedure

Questions Presented

  1. Whether the district court should grant a new trial under Rule 59(a) because the jury's verdict was against the weight of the evidence
  2. Whether the plaintiff established a prima facie equal protection claim

Holdings

  1. The motion for a new trial is denied because conflicting testimony and credibility determinations are not sufficient grounds for granting a new trial under Rule 59(a).
  2. The plaintiff failed to establish a prima facie case of racial discrimination, so the equal protection claim was not proven.

Key quotations

“authorizes a district court to override a jury verdict and order a new trial ‘if the verdict is against the law, against the weight of the credible evidence, or tantamount to a miscarriage of justice.’” (at 16)
“conflicting testimony or a question as to the credibility of a witness are not sufficient grounds for granting a new trial.” (at 551)

Factual background

At an October 17, 2017 Pawtucket City Council meeting, Officer Craig Letourneau approached plaintiff Cristina Bento, the only person of color in the audience. The parties dispute whether the officer's approach was racially motivated. The jury found that the officer’s actions were not based on race and credited his testimony over the plaintiff’s.

Procedural history

Case tried to a jury which returned a verdict for the defendants on all counts. Plaintiff filed a motion for a new trial under Rule 59(a) which was denied.

Court Document

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