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Sanders v. Correct Care Solutions, LLC

United States District Court, M.D. Tennessee, Nashville Division

May 25, 2018

VALERIE SANDERS, Plaintiff,
v.
CORRECT CARE SOLUTIONS, LLC, Defendant.

          Jury Demand Judge

          MEMORANDUM AND ORDER

          JEFFERY S. FRENSLEY U.S. Magistrate Judge

         Pending before the Court is the Plaintiff's Motion for New Trial (Docket No. 91) and Defendant's Response in opposition (Docket No. 95). For the reasons stated herein, the Plaintiff's Motion is DENIED.

         BACKGROUND

         Ms. Sanders filed this action pursuant to Title VII of the Civil Rights Act of 1964 on December 28, 2015, alleging employment discrimination based on race. (Docket No. 1). Specifically, she contends that because of her race, she was hired at a rate of pay that was less than similarly situated Caucasian employees and continues to be paid less. Id. Defendant Correct Care Solutions, Inc. (“CCS”) denied liability asserting their employment decisions were not based upon racial considerations. Docket No. 4. On February 15, 2018, the jury rendered a verdict for CCS and the clerk of Court entered a Judgment in CCS's favor. Docket No. 90. On March 14, 2018, Ms. Sanders filed a Motion for New Trial. Docket No. 91. CCS filed a response in opposition on March 28, 2018. Docket No. 95.

         STANDARD OF REVIEW

         Generally, a court may grant a new trial under Fed.R.Civ.P. 59(a) “if the verdict is against the weight of the evidence, if the damages award is excessive, or if the trial was influenced by prejudice or bias, or otherwise unfair to the moving party.” Conte v. Gen. Housewares Corp., 215. F.3d 628, 637 (6th Cir. 2000). The Sixth Circuit has explained that “the governing principle in the district court's consideration of a Motion for a New Trial is whether in the judgment of the trial court such course is required to prevent an injustice. . . .” Park West Galleries v. Hochman, 692 F.3d 539, 544 (6th Cir. 2012)(quoting Davis by Davis v. Jellico Cmty. Hosp. Inc., 912 F.2d 129, 133 (6th Cir. 1990)(internal quotation marks omitted)) The burden of demonstrating the necessity of a new trial is on the moving party, and the ultimate decision whether to grant such relief is a matter vested within the sound discretion of the district Court. Clarksville-Montgomery Co. Sch. Sys. v. U.S. Gypsum Co., 925 F.2d 993, 1002 (6th Cir. 1991). The party seeking a new trial bears “a heavy burden.” Miller v. American President Lines, Ltd., 989 F.2d 1450, 1456 (6th Cir. 1993). While the trial judge has great authority to grant new trials, the motion should be denied if the verdict is one that reasonably could have been reached, regardless whether different inferences and conclusions could have been drawn or other results are more reasonable. Walker v. Bain, 257 F.3d 660, 670 (6th Cir. 2001).

         ANALYSIS

         Rule 7(b) of the Federal Rules of Civil Procedures requires that motions state with particularity the grounds for seeking the Order. In the context of a Rule 59 motions for new trial, Rule 7(b) “does not require ritualistic detail but rather a fair indication to court and counsel the substance of the grounds” for the Motion. Fed. R. of Civ. P. 59 advisory committee's note to the 1966 amendment. The Sixth Circuit has indicated that the moving party's “grounds in its motion for new trial must be ‘reasonably specific' in order to comply with the particularity requirement imposed by Rule 7(b)(1).” Intera Corp. v. Henderson, 428 F.3d, 605, 612 (6th Cir. 2005) (quoting Black Industry Inc. v. Raulston Purina Co. 327 F.2d 266, 274 (8th Cir. 1964)). No final transcript of the trial been prepared or filed with the Court and therefore there are no citations to the record. However, the grounds set forth in Plaintiff's motion are “reasonably specific and offer a fair indication to the court and counsel of the substance of the grounds for the motion.

         The Plaintiff submits five assignments of error each of which she contends requires that the Court grant her a new trial in this matter. The Court will address each alleged error in turn, discussing as well the appropriate standard of review.

         A. Admissibility of CCS's Position Statement to the EEOC

         Prior to trial, CCS filed a Motion in Limine to Exclude the Testimony or Evidence Related to Documents Submitted to the EEOC in Response to the Plaintiff's EEOC Charge. Docket No. 48. The Court held a hearing on the motions in limine and reserved ruling on this motion. Docket No. 67. At trial, Plaintiff sought to introduce Defendant's position statement to the EEOC through the paralegal who prepared and provided the document to the EEOC. Docket No. 91-1. Plaintiff contends that it was error to exclude the document which referenced specific white employees as “true comparators” to the Plaintiff. Docket No. 91, pp. 3-4. Plaintiff submits “this evidence was critical to Plaintiff's case to demonstrate the comparator group was limited to the time frame argued by Plaintiff and that Defendant acknowledged the same to the EEOC.” Id. Plaintiff argues this error was compounded by allowing the Defendant “to significantly expand the comparator group to one that inured to its benefit at trial.” Id.

         The Defendant argues that Plaintiff's counsel conceded that the position statement itself was impermissible to submit to the jury.” Docket No 95, p. 2. They note that the Court did not prevent Plaintiff from asking the witness, Linda Callaway, if she ever referred to specific employees as “true comparators” and “because Plaintiff did not seek to impeach Ms. Callaway before attempting to use the position statement, the Court properly excluded it.” Id. at p. 3.

         The trial court's ruling on the admission of evidence is reviewed for abuse of discretion. Trepel v. Roadway Exp., Inc., 194 F.3d 708, 716 (6th Cir, 1999). An abuse of discretion is defined as “a definite and firm ...


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