8th Circuit increases punitive damages for tased teen

A federal appeals court has upheld a jury verdict for a man who sued an Independence police officer for injuries stemming from the use of a Taser and increased his punitive damages, which had been reduced post-trial. 

On May 27, the 8th U.S. Circuit Court of Appeals ruled in favor of Bryce E. Masters in his case against former Independence Police Officer Timothy Runnels. 

In 2014, Masters, then 17, was pulled over after a license plate check yielded an outstanding warrant mistakenly associated with the plate.

When Masters asked why he was being detained and whether he was under arrest, Runnels ordered him out of the car and ultimatley discharge his Taser into Masters’ chest. Masters alleged he went into cardiac arrest and that blood to his brain was cut off. 

Runnels was later terminated from the department and pleaded guilty to a federal charge of deprivation of rights under color of law. 

In 2018, a Jackson County jury awarded Masters $6.55 million on claims that Runnels discharged the Taser for a prolonged period of time into Masters’ chest, and that he dropped Masters while handcuffed and unresponsive onto a concrete driveway. 

After trial, U.S. District Judge Gary Fenner of the Western District of Missouri reduced the $50,000 in actual damages for the drop claim to $47,300, to account for a restitution payment that Runnels made. Fenner also found the $1 million in punitive damages for that claim was too high and reduced it to $236,500.

The 8th Circuit affirmed the verdict and held that Fenner correctly determined the initial punitive award on the drop claim was disproportionate but disagreed with the amount. The court said a 9-to-1 ratio between the actual damages and the punitive award was proper, bringing punitive damages for the drop claim to $425,700. 

“An appropriate ratio of punitive damages to compensatory damages on the drop claim must take into account the gravity of Runnels’s misconduct, as recognized by the jury, while remaining consistent with due process in light of the amount of the compensatory damages award,” Judge Jane Kelly said. Judge Michael J. Melloy agreed. 

In a concurring opinion, Judge Steven Colloton agreed that Fenner properly denied qualified immunity, but said he believed that Jackson v. Stair, a 2019 8th Circuit ruling the court cited in determining whether Runnels’ use of a Taser constituted excessive force, was wrongly decided. 

The award for the Taser claim wasn’t at issue on appeal. That award consisted of $5 million in actual damages (which was reduced to $2.9 million post-trial based on prior payments in the case) and $500,000 in punitive damages. 

The case is Masters v. Runnels et al., 19-2199.