United States District Court, S.D. Illinois
MEMORANDUM AND ORDER
NANCY J. ROSENSTENGEL, District Judge.
Before the Court is the Renewed Motion for Judgment as a Matter of Law, or in the Alternative, Motion for a New Trial (Doc. 117) filed by Defendant Rev. James Mutayoba. Plaintiff has filed a Response (Doc. 121) in opposition to the Motion. For the foregoing reasons, Defendant's Motion is denied.
Plaintiff, La'Shawn Wilson-El, formerly incarcerated at Robinson Correctional Center, brought this action for deprivations of his First Amendment rights pursuant to 42 U.S.C. § 1983. Specifically, Plaintiff, a member of the Moorish Science Temple of America ("MSTA"), alleged that the denial of his request for a vegan diet was a violation of his First Amendment Free Exercise rights.
At trial, Defendant testified that he believed his sole authority to grant or deny a religious diet was in the Chaplaincy Handbook of Religious Beliefs and Practices (the "Chaplaincy Handbook"). Defendant testified that he relied on the Chaplaincy Handbook when denying Plaintiff's vegan diet because the Chaplaincy Handbook said it was proper to do so. On cross-examination, Plaintiff displayed the following excerpts of the Chaplaincy Handbook to the jury:
An inmate has a right to receive a diet that is consistent with his religious beliefs. This is a constitutional right under the First Amendment. Making it very difficult for an inmate to obtain a diet required or motivated by his religion would be improper and could result in serious legal liability for the Department and for the individuals involved.
Upon transfer from one facility to another facility, an inmate should not have a problem continuing on the religious diet that he may have been getting for years elsewhere. If an inmate has been approved for a religious diet at one facility, this approval and diet should follow him automatically to any other facility. An inmate should not have to provide any further information or verification at the new facility that his religion practices the particular diet or that his request is sincere. To reiterate, once an inmate has received approval for a religious diet at a facility, that approval should remain effective, regardless of any facility transfers, for the entire term of his incarceration, absent some later indication for fraud or scam or abandonment of the religion. A transfer should not affect a religious diet approval.
Although section 425.70(c) of this Rule indicates an offender's request for a religious diet must cite membership in "a faith group that requires adherence to a particular diet, " IDOC does not require such faith group membership nor require that a religious diet be obligatory, but rather looks to individual religious sincerity in considering any inmate's religious diet request.
( See Doc. 121, pp. 5-6, citing Plaintiff's Trial Exhibit 20).
This matter proceeded to a three-day jury trial beginning on February 11, 2015. Defendant moved for judgment as a matter of law at the close of Plaintiff's case, which this Court denied. Defendant again moved for judgment as a matter of law regarding punitive damages at the close of Defendant's case. The Court took the motion under advisement. On February 13, 2015, the jury returned a verdict for Plaintiff. The jury awarded Plaintiff $1.00 in compensatory damages and $10, 100.00 in punitive damages (Doc. 106).
Standard of Review
A motion for judgment as a matter of law made during trial, which is denied by the Court may be renewed pursuant to Federal Rule of Civil Procedure 50(b). A Rule 50(b) motion should be granted only when "a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that issue." Murray v. Chicago Transit Auth., 252 F.3d 880, 886 (7th Cir. 2001). The standard governing a Rule 50(b) renewed motion for judgment as a matter of law is the same as used in determining a motion for summary judgment pursuant to Rule 56, meaning that the Court must review the entire record, construing all the evidence in favor of the nonmoving party. Appelbaum v. Milwaukee Metro. Sewerage Dist., 340 F.3d 573, 578 (7th Cir. 2003) (citing Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133, 150 (2000)).
Evidence is strictly construed "in favor of the party who prevailed before the jury, " and the Court may examine "the evidence only to determine whether the jury's verdict could reasonably be based on that evidence." Passananti v. Cook County, 689 F.3d 655, 659 (7th Cir. 2012). The Court does not make credibility findings or weigh the evidence and must disregard evidence favorable to the moving party that the jury was not required to believe. Id. at 659. The Seventh Circuit has stated that "overturning a jury verdict is not something [the court] do[es] lightly, " Massey v. Blue Cross-Blue Shield of Ill., 226 F.3d 922, 925 (7th Cir. 2000), and it will only do so if the ...