SLOVITER, Circuit Judge.
It is only on rare instances that a jury's verdict in a civil case should be overturned. This appeal presents the question whether this is such a case.
Courtland Pitts filed a Complaint against Corporal Gregory Spence of the Delaware State Police, asserting claims under 42 U.S.C. § 1983 and state law. After a trial, a jury found in favor of Pitts on two of his four claims. The District Court granted Spence's subsequent motion for judgment as matter of law, made pursuant to Rule 50 of the Federal Rules of Civil Procedure. Viewing the evidence in the light most favorable to Pitts, we conclude that the District Court erred.
Pitts' Complaint against Spence alleged that Spence falsely arrested, illegally seized, and maliciously prosecuted him, as well as deprived him of equal protection under the law. At trial, Pitts testified that his claims arose out of events occurring when Pitts, who is African American, went to Mitchem's Auto Body Shop and conversed with its owner, James Mitchem, Jr., who is Caucasian, about Pitts' displeasure with work Mitchem had done on Pitts' car. A verbal dispute between the men arose, which quickly escalated into a physical altercation. At some point, Mitchem "promised" to "[o]pen up a can of whoop ass" on Pitts, which Mitchem conceded was intended to convey a physical threat. App. at 328-29. The men brawled and Pitts knocked Mitchem to the ground by punching him after Mitchem lost his balance.
After Mitchem fell, Daniel Wykpisz, a shop employee who had witnessed the altercation and who is Caucasian, grabbed an aluminum baseball bat from the shop and chased Pitts from the area. During the chase, Pitts came across a board, which he picked up to defend himself. Wykpisz then stopped giving chase, turned around, and walked back to the shop.
Pitts testified that he walked back to his car, which he had parked in the common parking lot shared by the numerous industrial shops in the area, and discovered that his car windshield and hood had sustained fresh damage. Mitchem later admitted responsibility for causing the damage. While Pitts was near his car, Mitchem threatened him by saying "[y]ou better get the F out of here or I'll get my gun." App. at 252. Pitts dialed 9-1-1 several times, conveying to the dispatcher that he had been chased with a baseball bat and that Mitchem had threatened him with a gun. Wykpisz and Mitchem testified they had also called 9-1-1. At least two officers responded to the calls, including Spence, who is Caucasian, and another officer, Corporal Helen Dane.
Although the exact sequence of events is unclear, Pitts testified that when Pitts saw Spence's patrol car, he started waving his arms to identify himself as the person who called for assistance. Spence, who had received a report that there might be a gun at the scene, acknowledged Pitts by rolling down his window slightly and yelling, "[g]et back, get back." App. at 255. Pitts accused Spence of treating him unfairly, exclaiming "[i]f I was a white guy, you would have been out of that car, and I would have been treated differently." Id. According to Pitts, Spence then jumped out of his patrol car, got in Pitts' face, and when Pitts asked for Spence's badge number and supervisor's name, told Pitts to "[s]hut the fuck up." App. at 256.
Pitts and Spence hollered at each other and Spence eventually told Pitts that "[i]f you don't shut the fuck up, I'm going to arrest you." App. at 257. Pitts put his hands behind his back and told Spence that he was not going to resist. Spence handcuffed Pitts and placed him in the backseat of the patrol car, but did not read Pitts his rights under Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966).
Pitts testified that he was unable to tell Spence about Mitchem's threats or that Wykpisz chased him with a bat because Spence "never gave [Pitts] a chance" and "didn't want to hear anything [Pitts] had to say." App. at 276. Pitts declined to give a statement but Spence continued his investigation by speaking with Mitchem and Wykpisz, who gave a narrative of the events and informed Spence that Pitts had made the gun threat. Pitts did not see Spence question any of the numerous witnesses who had gathered at the scene.
Spence towed and conducted an inventory search of Pitts' car. The inventory search produced nothing incriminating. Spence did not report finding a weapon.
The parties' briefs do not discuss the state court trial based on the charges against Pitts on one hand and Mitchem on the other. Pitts was acquitted of all the charges brought against him. Pitts asserts that Mitchem pled no contest to two of the charges against him, and that the third was dropped pursuant to a plea agreement.
Following the state court proceedings, the District Court proceeded to hear the instant suit, which Pitts had filed against Spence. The jury returned a verdict, pursuant to a general verdict form, finding in favor of Pitts on his illegal seizure and equal protection claims, and in favor of Spence on Pitts' false arrest and malicious prosecution claims. The jury awarded Pitts $80,000 in compensatory damages and $1,000 in punitive damages. Spence filed a motion for judgment as matter of law, which the District Court granted.
In granting the motion, the District Court noted that the parties' agreed-upon instructions presented the jury with two possible scenarios that could support Pitts' claim of illegal seizure: (1) when Spence handcuffed and placed Pitts in the back of the patrol car; and (2) when Spence towed and conducted an inventory search of Pitts' car.
The Court next considered whether there was sufficient evidence to support the jury's illegal seizure verdict insofar as it was based on the search and seizure of
Turning to the jury's verdict in favor of Pitts on his equal protection claim, the Court was not persuaded that Spence's failure to properly document or investigate the incident could support the jury's verdict, reasoning that "any gaps in the police report concerning Mr. Pitts' point of view are attributable to [Pitts'] own lack of cooperation" in declining to give a statement to Spence after Spence attempted to interview him. Id. at 487. The Court rejected Pitts' other arguments, concluding that there was "no evidence" that Spence acted with discriminatory purpose or that his actions were in any way motivated by racial animus. Id. at 486. The Court therefore granted Spence judgment as a matter of law on Pitts' equal protection claim.
Having overturned both of the jury's verdicts in favor of Pitts, the Court denied the motions of Pitts' current and former counsel made pursuant to 42 U.S.C. § 1988 for attorneys' fees and expenses, on the basis that Pitts was no longer a prevailing party. Pitts appeals.
The District Court had jurisdiction pursuant to 28 U.S.C. § 1331 and this court has appellate jurisdiction pursuant to 28 U.S.C. § 1291. We exercise plenary review over the District Court's decision to grant judgment as a matter of law, viewing the record evidence in the light most favorable to Pitts, as the verdict winner, and drawing all reasonable inferences in his favor. We have cautioned that a court should grant judgment as a matter of law "sparingly." Johnson v. Campbell, 332 F.3d 199, 204 (3d Cir.2003). A court must not weigh evidence, engage in credibility determinations, or substitute its version of the facts for the jury's. Only if the record is "critically deficient of the minimum quantum of evidence" upon which a jury could reasonably base its verdict will we affirm a court's grant of judgment as a matter of law. Acumed LLC v. Advanced Surgical Servs., Inc., 561 F.3d 199, 211 (3d Cir.2009) (internal quotation omitted).
Pitts contends that the District Court erred in concluding that the evidence was insufficient to support the jury's illegal seizure verdict in his favor. Pursuant to the parties' agreement, the Court instructed the jury that the Fourth Amendment "protects persons from being subjected to unreasonable searches and seizures by police." App. at 520. The Court explained that Pitts was required to demonstrate by a preponderance of the evidence: (1) that Spence "intentionally handcuffed [Mr. Pitts], and placed him in the back seat of a patrol vehicle, and towed and impounded [his] vehicle[;]" (2) "that those acts subjected Mr. Pitts to a seizure[;]" and (3) that
We agree with Pitts that the evidence was sufficient to permit the jury to conclude that Spence subjected Pitts to an unlawful seizure.
Moreover, it was error for the Court to rely on Fourth Amendment principles regarding investigatory detentions because the jury was not instructed on that jurisprudence. Even if Spence had an articulable suspicion that Pitts had committed a crime, the jury was informed only of the law regarding probable cause. The jury could have concluded on the evidence that probable cause was lacking; and thus, based on the instructions given, the evidence was sufficient to support Pitts' claim that Pitts' detention was unlawful.
With regard to the towing and inventory search of Pitts' car, Spence conceded at trial that he lacked probable cause to conduct a search of Pitts' car. Spence testified that he considered the towing necessary to prevent the possibility of another altercation or further damage to Pitts' car, and conceded that he did not search the car for safety reasons or to look for a gun. The jury, however, could have found that Spence was not credible and could have concluded that Spence unlawfully searched the car in order to search for the gun that Mitchem had accused Pitts of threatening to use. The Court necessarily weighed the evidence and did not view it in the light most favorable to Pitts when it concluded that there was no evidence to support a suggestion of pretext and that Spence's asserted fear rendered the towing and inventory search reasonable as a matter of law. It was also error for the Court to consider inventory-search jurisprudence in its analysis because the
Pitts further asserts that the District Court erred in concluding that the evidence was insufficient to support the jury's verdict in Pitts' favor on his equal protection claim. The Court informed the jury that "[t]he Equal Protection Clause of the 14th Amendment to the United States Constitution ... guarantees each and every person that they will not be denied their fundamental rights in an arbitrary or discriminatory manner." App. at 518. The Court explained that it was Pitts' burden to demonstrate by a preponderance of the evidence that Spence was motivated by a discriminatory purpose, or "an intent or purpose to discriminate against [Pitts] ... based upon [Pitts]' membership in a protected class." App. at 519. It was also Pitts' burden to demonstrate that Spence's conduct had a discriminatory effect, which "is shown where the plaintiff is a member of a protected class, he is similarly situated to members of that class, and that he was treated differently than members of the unprotected class." App. at 519-20. The jury was informed that it could consider direct or circumstantial evidence in its deliberations and that neither form of evidence was superior to the other.
We agree with Pitts that the evidence circumstantially demonstrated that Spence violated Pitts' rights to equal protection. For example, the jury was entitled to consider Spence's admittedly inaccurate reporting of the incident. Spence acknowledged that he did not record that he spoke with Pitts first upon arriving at the scene, that Pitts accused Spence of being racist, that Spence handcuffed Pitts and placed him in his patrol car before interviewing Mitchem and Wykpisz, or that Spence did not try to interview Pitts after he concluded his investigation. Spence explained that he "didn't feel the need" to explain and that "there was no reason to say" that Pitts had accused Spence of being racist because that exchange was "irrelevant to the crimes that occurred between [Pitts] and Mr. Mitchem." App. at 405-06. The jury, however, was entitled to disregard this testimony as incredible. The District Court's conclusion that Spence's inaccurate reporting was the fault of Pitts' decision to remain silent, a right that he was entitled to exercise under the Fifth Amendment, was not only in direct conflict with Spence's testimony, but also necessarily resulted from the Court's substitution of its view of the facts for the jury's.
The jury was also entitled to consider Spence's testimony regarding his manner of investigating the incident. Spence admitted that he did not question Mitchem's statement that Pitts told Mitchem that he was going to get a gun. Indeed, Spence's crime report made no mention of Spence having interviewed anyone other than Wykpisz or Mitchem at the scene.
Similarly suggesting an equal protection violation was the testimony of Pauline Reid, a witness to the altercation and Pitts' confrontation with Spence. Reid testified that Spence was "agitated" and "elevated" when speaking with Pitts, and "was not listening to what [Pitts] was trying to explain." App. at 304, 305, 309. Reid confirmed that she was so concerned for Pitts' wellbeing after watching Spence's demeanor towards him that she followed Pitts in Spence's patrol car back to the police station. She stated that she felt Pitts had been treated unfairly because the officers "bypassed [Pitts] and went to the other person. They didn't really listen to [Pitts]. When they came back, no one was listening...." App. at 309. This observation of unequal treatment supported Pitts' assertion that Spence treated him dismissively. The testimony circumstantially demonstrated that Spence acted with a discriminatory purpose and effect.
The jury could have also given weight to Spence's post-investigation conduct. Spence charged Pitts with aggravated menacing, a charge that requires that the defendant place the victim in fear of imminent physical injury, 11 Del. C. § 602(a), for having "CHASED VICTIM WYKPISZ WITH A LONG WOODEN POLE." App. at 67. At trial, however, Wykpisz testified that he was not afraid that Pitts would strike him, and in fact turned his back to Pitts to walk back to the shop. The jury could have concluded that Spence was aware that Wykpisz did not feel threatened, and acted with discriminatory purpose and effect by bringing an improper charge against Pitts.
The above sampling of evidence, much of which the District Court failed to mention, was sufficient to support the jury's verdict in favor of Pitts on his equal protection claim. In concluding that there was no evidence that Spence was motivated by a discriminatory purpose and engaged in conduct that had a discriminatory effect, the Court necessarily weighed the evidence, engaged in credibility determinations, and substituted its view of the facts for the jury's. This exceeded the Court's role and was therefore in error.
This case does not present one of those infrequent occasions in which the record