Summary
The United States District Court for the District of Connecticut resolves disputes concerning proposed jury instructions in Stefon Morant’s Section 1983 action against the City of New Haven and individual defendants. The Court approves instructions requiring proof of but-for and proximate causation, addresses the deliberate-indifference standard for Monell liability, declines to instruct the jury on Connecticut General Statutes § 7-465, and determines that nominal damages instructions are inappropriate.
Court
United States District Court for the District of Connecticut
Jurisdiction
United States District Court for the District of Connecticut
Decision date
May 24, 2026
Docket number
3:22-CV-630 (SVN)
Disposition
other
Questions Presented
- Whether the jury should be instructed that but-for and proximate causation are required for Morant's § 1983 claims, including his Brady and Monell claims.
- Whether the jury should receive Morant's proposed deliberate-indifference Monell instruction concerning whether a municipal policymaker knew or should have known that an omission was substantially certain to result in a constitutional violation.
- Whether the jury should be instructed on Connecticut General Statutes § 7-465 and determine whether individual defendants' conduct was willful or wanton.
- Whether the verdict form should include nominal damages or separate compensatory-damages lines for each defendant.
Holdings
- The court approved an instruction requiring Morant to prove both but-for causation and proximate causation for each § 1983 claim, including the Monell claim, while declining to decide whether Second Circuit law independently requires that standard because all parties agreed to the instruction.
- The court approved an instruction requiring Morant to show that, based on facts available to Chief Pastore, the policymaker knew or should have known that the particular omission was substantially certain to result in a constitutional violation, while retaining the requirement of more than mere negligence and a conscious choice not to act.
- The court declined to instruct the jury on § 7-465 or require jury findings under that statute. With the exception of Sweeney's objection, the parties consented to the court deciding whether the individual defendants' conduct was willful or wanton if liability was found; the court overruled Sweeney's objection in light of the existing partial summary judgment against him.
- The court declined to include an instruction or verdict-form question on nominal damages and required a single compensatory-damages line rather than separate lines for each defendant.
Court Document
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