AELE LAW LIBRARY OF CASE SUMMARIES:
Civil Liability of Law Enforcement Agencies & Personnel
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Damages: Punitive Individual
A man served his
full ten year sentence for rape and residential burglary, after which his
conviction was vacated because of newly available DNA evidence. He sued
a police detective involved in his case, accusing him of fabrication of
evidence. Overturning a trial court's dismissal of the lawsuit, a federal
appeals court found that the claim did not accrue until the plaintiff was
acquitted of all charges, so that the lawsuit was filed in a timely fashion
within the applicable three year statute of limitations and was not time
barred. The appeals court did not address the detective's qualified immunity
defense, as the court below had not reached the issue. Bradford v. Scherschligt,
#14-35651, 803 F.3d 382 (9th Cir. 2015).
A federal court jury awarded a total of approximately $97.5 million for the police shooting death of a man who was the former mayor of Cottageville, South Carolina. Damages awarded included $7.5 million in compensatory damages, as well as $90 million in punitive damages--$60 million against the town and $30 million against the officer. The officer who shot the decedent had been hired by the department after being previously fired by a number of other police departments for insubordination, dangerous use of firearms, and other alleged infractions. The officer claimed that the shooting was in self-defense because the decedent threw "wild" punches at him. His attorney argued that the decedent suffered from a bipolar disorder and was enraged during the incident. The plaintiffs contended that the decedent had complained about the officer, who wrote traffic tickets worth over $600,000 from 2008 to 2011, more than any other officer on the force, and that the shooting was retaliatory for the decedent's complaints intended to get rid of the officer because of his aggressive policing. Reeves v. Town of Cottageville, #2:12-cv-02765, U.S. Dist Ct., (D.S.C. Oct. 15, 2014). In an earlier decision, the trial judge commented that evidence of the officer's departure from six other law enforcement agencies in seven years was "obviously admissible" against him with respect to the claim that the town and police department negligently hired, retained, and supervised the officer, and a claim for municipal liability for violation of civil rights. This evidence, the court ruled, had a bearing on whether the municipal defendants properly evaluated the officer's credentials befire hiring him. Reeves v. Town of Cottageville, #2:12-cv-02765, 2014 U.S. Dist. Lexis 120619 (D.S.C.).
A Vietnam veteran suffering from severe post-traumatic stress disorder was combative and disoriented at a hospital emergency room, where his family had brought him for treatment of an injury. Two police officers placed him under arrest under a state mental hygiene law as a person who appears mentally ill and acts in a way likely to cause serious harm to himself or others. He and an officer subsequently fought while he was handcuffed. The arrestee claimed that a beating from the officer aggravated his existing back pain and post-traumatic stress disorder. The jury in an excessive force lawsuit awarded $60,000 in compensatory damages and $300,000 in punitive damages. A federal appeals court upheld the award, although ruling that either the plaintiff would have to accept a reduction of punitive damages to $100,000 or undergo a new trial on the punitive damages issue. The appeals court also found that the trial court had not abused its discretion by denying the defendant officer's motion for a continuance after an illness prevented him from attending the first three days of the five-day trial. Payne v. Jones, #09-5201, 2012 U.S. App. Lexis 20665 (2nd Cir.).
After a city's mayor complained to police that her neighbor, a single mother, was allowing her children to run wild through flower beds in the neighborhood, an officer allegedly knocked the mother to the ground and dragged her to his vehicle, placing her inside it. One of her children opened the door of the police car, and she fled the vehicle. The officer then placed her under arrest for escape. A federal appeals court upheld a verdict for the mother in her false arrest lawsuit. Based on the evidence, a reasonable jury could find that the officer initially arrested her without probable cause to do so, so that she was justified in fleeing. The court upheld an award of $57,400 in compensatory damages, but ordered the reduction of a $1 million punitive damages award to $550,000. Arnold v. Wilder, #08-6124, 2011 U.S. App. Lexis 18928 (6th Cir.), rehearing, en banc, denied, 2011 U.S. App. Lexis 21896 (6th Cir.). Editor's note: The appeals court ruled that the trial judge had erred in reducing the punitive damages award too far, to $229,600, "mechanically applying a four to one ratio" of punitive to compensatory damages.
The mother of a man shot in the head and killed by an officer sued the city for wrongful death. A jury awarded damages. An intermediate appeals court found that the trial judge had properly set aside $3 million in damages awarded for conscious pain and suffering, as the man's death was almost instantaneous and there was no evidence of his consciousness for any period of time following the shooting. The appeals court upheld, however, jury awards of $55,020 for loss of past economic support, $261,091 for past and future loss of services, and punitive damages of $2.7 million, finding them amply supported by the evidence. The appeals court stated that the trial judge had improperly concluded that the jury awarded punitive damages in part on a finding that the officer had negligently handled his weapon. The appeals court found that the jury award of punitive damages was based on a finding of excessive force, and conduct that was wanton, reckless or malicious. Ferguson v. City of New York, #2630, 18951/01, 2010 N.Y. App. Div. Lexis 4428 (1st Dept.).
A jury awarded a construction supervisor a total of $35,000 in compensatory and $350,000 in punitive damages on a false arrest claim against a mayor and police. The punitive damages award was ruled to be grossly excessive, and in violation of due process, particularly as the mayor had no fair notice that he might face a penalty of that size. The trial court therefore properly reduced the punitive damages award to $35,000. Mendez-Matos v. Municipality of Guaynabo, No. 07-2303, 2009 U.S. App. Lexis 3702 (1st Cir.).
An arrestee was awarded $1 in nominal damages and $250,000 in punitive damages against a police officer in a lawsuit arising out of a shooting by an officer resulting in the death of her deaf-mute son. The lawsuit did not challenge the legality of the shooting, but claimed that officers improperly acted against the arrestee and her other surviving son following the shooting. The claims asserted included an allegedly unlawful search of the arrestee's house and false arrest. The appeals court upheld a reduction of the punitive damages to $5,000, finding that the jury's award was unconstitutionally excessive. The appeals court found that she did not present enough to create a triable issue concerning the county's alleged negligent training of the officers, and upheld a jury instruction limiting the plaintiff's claim for emotional distress damages to the distress experienced during the two days surrounding the incident. The appeals court also overturned an order denying the plaintiff attorneys' fees as a sanction for her attorney's failure to appear at a hearing, since he did not have any notice that a personal appearance was required. Mendez v. County of San Bernardino, No. 05-56118, 2008 U.S. App. Lexis 18426 (9th Cir.).
In a prior decision, Campbell v. Miller, 06-1981, 499 F.3d 1 (7th Cir. Ind., 2007), an appeals court ruled that no reasonable jury could find that a strip search and visual inspection of an arrestee's anal cavity, conducted in a backyard within the sight of others for no identified reason complied with the Fourth Amendment. The appeals court found that the officer who conducted the search was liable to the arrestee, while the city that employed him was not, as it did not have a policy that caused the manner in which the search had been conducted. In a hearing on damages on remand, the trial court ruled that the plaintiff was barred from seeking to recover punitive damages because a conclusive ruling on the issue had been reached at trial, and the arrestee had failed to challenge that portion of the court's rulings during the appeal. Campbell v. Miller, #1:03-cv-180, 2008 U.S. Dist. Lexis 501 (S.D. Ind.).
An award of $79.5 million in punitive damages in a case involving an award of $821,000 in compensatory damages violated due process and amounted to an unconstitutional taking of property when the jury was motivated in part by a desire to punish the defendant for allegedly harming persons who were not parties to the litigation. The case involved claims against a tobacco company, rather than claims about law enforcement, but the analysis in it, rejecting the roughly 100-to-1 ratio the punitive damage award bore to the compensatory damages amount as "grossly excessive" may be useful in also defending law enforcement personnel against excessive punitive damage awards. Philip Morris USA v. Williams, No. 05-1256, 127 S. Ct. 1057 (2007).[N/R]
Federal appeals court upholds $1.3 million award of compensatory and punitive damages against police officers for allegedly using excessive force against two arrestees. Evidence was sufficient for a reasonable jury to arrive at a finding of liability, and the defendants failed to preserve for appeal any question about whether the compensatory damages awarded were excessive. The punitive damages award of $250,000 against each of the four defendants was not excessive under the circumstances if the jury believed the plaintiffs' version of the incident, amounting to an unjustified assault by the officers. Casillas-Diaz v. Palau, No. 04-1303, 463 F.3d 77 (1st Cir.). [N/R]
Evidence supported jury verdict that a series of traffic stops, equipment compliance citations, and a vehicle impoundment were carried out against a California man to unlawfully retaliate against him for his protected free speech activity of complaining about a California Highway Patrol officer to his department. Federal appeals court upholds award of $500,000 in compensatory damages, but rules that punitive damage awards of $4 million were excessive and must be substantially reduced. Plaintiff also receives $800,000 in attorneys' fees. Grassilli v. Barr, No. D044931, 2006 Cal. App. Lexis 1384 (Cal. 4th App. Dist.). [2006 LR Nov]
Federal court did not have jurisdiction over lawsuit by car theft victim claiming that his vehicle was stolen by a theft ring operated by employees of the D.C. police department and that fraud was committed against him by the employees allegedly not entering his car's vehicle identification number into a stolen vehicle database. These claims, filed in federal court on the basis of diversity jurisdiction, require a showing that the amount at issue exceeds $75,000, but the value of the plaintiff's car was only $500, and an award of punitive damages of over $69,500 would be constitutionally excessive, making it clear that the amount at issue in the lawsuit was far less than the required amount. Hunter v. District of Columbia, No. CIV.A. 04-0303, 384 F. Supp. 2d 257 (D.D.C. 2005). [N/R]
Casino security officer, licensed to make warrantless arrests on her employer's premises under Michigan law, acted under color of state law in detaining 72-year-old woman for picking up a five cent token from the tray of an unoccupied slot machine. Federal appeals court upholds jury determination that the detention was an unlawful arrest and violated the woman's civil rights. $875,000 punitive damage award, however, ordered reduced to $600,000 in lawsuit in which plaintiff was only awarded $279.05 in compensatory damages. Romanski v. Detroit Entertainment, No. 04-1354, 2005 U.S. App. Lexis 23336 (6th Cir.). [2005 LR Dec]
Failure to instruct jury that it could impose punitive damages for officer's alleged excessive use of force against an arrestee if he acted in an "oppressive" manner required a new trial on the issue. Federal appeals court also orders recalculation of attorneys' fees award to determine whether hours plaintiff's attorney spent on unsuccessful claims were related to the time spent on the successful excessive force claim which resulted in $18,000 jury award of compensatory damages. Dang v. Cross, No. 03-55403, 2005 U.S. App. Lexis 17981 (9th Cir.). [2005 LR Oct]
Iowa deputy violated due process rights of non-custodial father when he removed 12-year-old visiting daughter from his home after seeing her in the presence of an accused sexual offender, and failed to notify juvenile court of the removal. Father had a protected liberty interest in connection with his daughter's visitation. Jury improperly awarded $30,000 in punitive damages, however, based on improper jury instructions that failed to require a showing or either evil motive or reckless indifference to protected federal rights. Swipies v. Kofka, No. 04-3244, 2005 U.S. App. Lexis 16861 (8th Cir.). [2005 LR Oct]
Trial court properly reduced, by 20%, attorneys' fees to be awarded to plaintiff arrestee who prevailed against one officer on false arrest and abuse of process claims and was awarded $50,000 in compensatory and $8,508 in punitive damages. Reduction was justified by the fact that no evidence supported other claims which the plaintiff voluntarily withdrew one week prior to trial, and that the jury returned a verdict against the plaintiff on claims for malicious prosecution and battery. Green v. Torres, No. 02-7658, 361 F. 3d 96 (2nd Cir. 2004). [N/R]
Police officer's conduct in allegedly refusing to provide a man protection against his ex-girlfriend, a fellow police officer, following purported threats of physical violence, was "reprehensible" enough to support an award of punitive damages, but court finds $200,000 jury award of punitive damages excessive, ordering it reduced to $25,000, while upholding $2,000 award of compensatory damages. Plaintiff would be granted a new trial limited solely to the issue of punitive damages if he rejected the reduction. Stack v. Jaffee, 306 F. Supp. 2d 137 (D. Conn. 2003). [N/R]
Jury award of $300,000 in compensatory and $1 million in punitive damages to arrestee and estate of second arrestee (who committed suicide months after arrest) on excessive force claims was not excessive. Diaz v. Vivoni, 301 F. Supp. 2d 92 (D. Puerto Rico 2003). [N/R]
Two police officers were each properly assessed $10,000 in compensatory and $20,000 in punitive damages, appeals court rules, for unreasonable and "unnecessarily degrading" and prolonged detention of female resident of home who was not a subject of their investigation during the execution of a search warrant. Plaintiff was allegedly kept in handcuffs for several hours, marched barefoot through the rain, and unnecessarily questioned about her citizenship status. Mena v. City of Simi Valley, #01-56673, 332 F.3d 1255 (9th Cir. 2003). [2003 LR Sep]
Evidence was sufficient for jury to award $15,000 to man beaten by police officer while sergeant stood by, but an award of $2 million in punitive damages was excessive, federal trial court rules, citing new U.S. Supreme Court case on proportionality of punitive damages to compensatory damages. Trial judge orders reduction of punitives to 45,000 or else a new trial on the issue of punitive damages. Waits v. City of Chicago, No. 01C4010, U.S. Dist. Ct. N.D. Ill. June 6, 2003, reported in Chicago Daily Law Bulletin, p. 1 (June 9, 2003). [2003 LR Jul]
U.S. Supreme Court holds that a punitive damages award of $145 million was excessive in a case where the compensatory damages were $1 million. Such a disproportionate award of punitive damages violates the Due Process Clause of the Fourteenth Amendment. Courts reviewing punitive damages should consider: (1) the degree of reprehensibility of the defendant's misconduct, (2) the disparity between the actual or potential harm suffered by the plaintiff and the punitive damages award, and (3) the difference between the punitive damages awarded by the jury and the civil penalties authorized or imposed in comparable cases. State Farm Mutual Automobile Insurance Co. v. Campbell, #01-1289, 123 S. Ct. 1513 (2003). [N/R]
Jury could reasonably conclude that an arresting officer used excessive force in light of arrestee's claim that he was an "innocent bystander" and had done nothing to provoke the officer except express his concern about alleged mistreatment of others, and that the officer continued to use force against him after he was in custody and subdued. Force allegedly used included throwing the arrestee to the ground after he was handcuffed, striking him in the back of the head, and kneeing him. Award of $5,000 in compensatory damages and $50,000 in punitive damages was not excessive when plaintiff had injuries resulting in $173 in medical expenses and claimed that he suffered fear, pain, and humiliation because of the officer's actions. Burbank v. Davis, 238 F. Supp. 2d 317 (D. Maine 2003). [N/R]
Jury properly awarded damages to estate of man shot and killed as he held his mother hostage with a knife and threatened to kill her if his ex-girlfriend was not brought to him, D.C. high court rules, but jury's $2.1 million compensatory damages award is reduced to $180,000, and $3.999 million punitive damage award was improper since there was no evidence to support a finding that the officers shot the decedent with an "evil motive" or "actual malice." District of Columbia v. Jackson, No. 99-CV-756, 810 A.2d 388 (D.C. 2002). [2003 LR Mar]
Jury properly awarded compensatory damages of $15,184 and punitive damages of $37,916 to bystander documenting police conduct at event who claimed that an officer assaulted him and tackled him to the ground while he had his hands up in the air. Defendant officer was not unfairly prejudiced by the admission of evidence concerning the conduct of other officers present on the occasion. Cummings v. Libby, 176 F. Supp. 2d 26 (D. Maine 2001). [2002 LR May]
Florida state statute putting a cap on punitive damages, F.S.A. Sec. 768.73, did not apply to arrestee's claim for intentional violation of his civil rights. Statute's limit on the amount of punitive damages applied to negligence, strict liability, and products liability, rather than intentional wrongs. Appeals court orders further proceedings, however, on whether award of $102,500 in compensatory and $330,000 in punitive damages against off-duty deputy was justified under the facts or was excessive. St. John v. Coisman, No. 5D00-3031, 799 So. 2d 1110 (Fla. App. 5th Dist. 2001). [2002 LR Mar]
Damage award of $3.5 million in non-economic damages to an arrestee who suffered the loss of one eye and an impairment to his left hand in an alleged assault by police officers was excessive under both federal and Maryland state law. Punitive damage awards of $150,000 each against two officers and $100,000 against a third were also excessive. Court orders reduction of non-economic compensatory damages to $1.25 million and of punitive damages to $50,000 each against two offices and $35,000 against a third, or, in the alternative, a new trial on damages. McCollum v. McDaniel, 136 F. Supp. 2d 172 (D. Md. 2001). [N/R]
346:147 Los Angeles arrestee could pursue federal civil rights claims against present and former city council members and current and former city attorneys, based on their role in allegedly deciding in "bad faith" to indemnify police officers assessed punitive damages by juries in past civil rights lawsuits. Blumberg v. Gates, 144 F. Supp. 2d 1221 (C.D. Cal. 2001).
343:101 City legislators are not entitled to qualified immunity if they act in bad faith in indemnifying police officers against awards of punitive damages in federal civil rights lawsuits for misconduct. Navarro v. Block, No. 99-55623, 250 F.3d 729 (9th Cir. 2001).
343:101 Rather than merely reviewing punitive damage awards for "abuse of discretion" by trial courts, federal appeals courts should conduct an "independent review" of whether such awards are so excessive as to be unconstitutional, U.S. Supreme Court rules. Cooper Industries, Inc. v. Leatherman Tool Group, Inc., No. 99- 2035, 121 S. Ct. 1678 (2001).
340:53 New York appellate court reduces total damages awarded for emotional distress, false arrest, and malicious prosecution from jury's award of $250,000 to $135,000, including reduction in punitive damages from $100,000 to $50,000. Lynch v. County of Nassau, 717 N.Y.S.2d 248 (A.D. 2000).
26:27 UPDATE Danish mother who left sleeping infant outside restaurant in carriage was not falsely arrested, New York federal jury finds, but still awards her $66,400 in damages for post-arrest damages, including alleged police department practice of failing to advise foreign arrestee of their right to seek assistance from their country's consulate; $1 each awarded to woman and the father of her baby for strip search. Sorensen v. City of New York, U.S. Dist. Ct., S.D.N.Y., reported in The New York Times, p. A23 (Dec. 15, 1999).
330:85 Federal appeals court upholds $245,000 award of compensatory and punitive damages to three 17- year-old boys, two African-American and one white, on claim that two police officers illegally stopped and searched their vehicle and used excessive force, including pulling and squeezing their testicles, during pat-down search, and were motivated by racial bias in carrying out one-hour stop, search and detention; alleged racial bias was a proper basis for punitive damages award. Price v. Kramer, #97-56580, #98-55484, 200 F.3d 1237 (9th Cir. 2000).
302:19 Arrestee was only entitled to one award of $1,000 when jury found that those were the damages he suffered; jury's action in then awarding him this amount on each of three claims--false arrest/imprisonment, malicious prosecution, and abuse of process--resulted in impermissible multiple recovery; Rhode Island Supreme Court also overturns $75,000 punitive damage award against municipality as improper. Graff v. Motta, 695 A.2d 486 (R.I. 1997).
290:25 Evidence adequately supported claim that police investigator coerced bank teller supervisor's confession to taking money from vault; jury awards $150,000 in compensatory damages and $200,000 in punitive damages against police investigator, and trial court finds punitive award excessive Niemann v. Whalen, 928 F.Supp. 296 (S.D.N.Y. 1996).
294:83 City's action of indemnifying police officers against punitive damages award in lawsuit brought over shooting death of fast-food restaurant robber did not constitute a policy of "encouraging and ratifying" the excessive use of force; individual city council members who voted for payment of punitive damages award were also entitled to qualified immunity for their action Trevino v. Gates, 99 F.3d 911 (9th Cir. 1996).
298:150 Federal appeals court rules that punitive damages award of $200,000 was excessive in malicious prosecution lawsuit in which jury awarded $1 in nominal damages against arresting officer Lee v. Edwards, 101 F.3d 805 (2nd Cir. 1996).
282:93 Warrantless search of home seeking for child was unreasonable, but plaintiff was not entitled to an award of attorneys' fees after only nominal damages were awarded; plaintiff waived issue of punitive damages by failing to raise it after verdict on liability was announced but before jury had been dismissed Caruso v. Forslund, 47 F.3d 27 (2nd Cir. 1995).
285:140 Evidence of arrestee's acquittal on criminal charges growing out of altercation with off-duty officer was properly admitted since favorable termination of criminal case was a necessary element of malicious prosecution claim; Rhode Island Supreme Court upholds $20,000 compensatory damages award, but rules that $50,000 punitive damages award against officer was excessive and that $10,000 would be a more appropriate amount of punitive damages Minutelli v. Boranian, 668 A.2d 317 (RI 1995).
285:131 U.S. Supreme Court rules that an award of punitive damages which was 500 times the size of the compensatory damages awarded by a jury was "grossly excessive" and constitutionally violative of the Due Process Clause of the Fourteenth Amendment BMW of North America, Inc v. Gore, 116 S.Ct. 1589 (1996).
275:167 Jury instruction informing it that city would indemnify officer for compensatory damages and attorney's statement to jury that city could indemnify officer for punitive damages required new trial on issue of compensatory and punitive damages awarded in federal civil rights suit against officer by detainee Larez v. Holcomb, 16 F.3d 1513 (9th Cir. 1994).
U.S. Supreme Court holds that $10 million punitive damage award did not violate due process. Pacific Mutual Life Ins Co v. Haslip, 499 U.S. 1 (1991).
Award of $880,000 to rental agent arrested on charges of leasing premised to be used for prostitution reversed on appeal; officers were entitled to qualified immunity Von Stein v. Brescher, 904 F.2d 572 (11th Cir. 1990).
Arrestees acquitted in criminal trial could claim their attorneys' fees in criminal defense as element of damages in civil rights suit against arresting officers Borunda v. Richmond, 885 F.2d 1384 (9th Cir. 1989).
Oregon supreme court holds that state statute limiting damages to $100,000 and barring punitive damages in suits against public entities and employees violates constitution in section 1983 cases Rogers v. Saylor, 760 P.2d 232 (Or 1988).
Officer liable for $20,000 in punitive damages for alleged beating of motorist following traffic accident Coulter v. Vitale, 882 F.2d 1286 (7th Cir. 1989).
Failure to separate claims for punitive damages for each defendant an on each cause of action required a new trial on punitive damages Staudacher v. City of Buffalo, 547 N.Y.S.2d 770 (A.D. 1989).
Plaintiff allowed to increase the amount of damages sought from $500,000 to $10 million ten years after filing his lawsuit alleging assault by police officers Suarez v. City of New York, 564 N.Y.S.2d 393 (A.D. 1991).
Punitive damages award against officers for use of excessive force during search upheld despite exceeding compensatory damages awarded by a ratio of up to 300/1; Punitive damages award against police chief overturned, but court holds that his statements to the press stating that plaintiff was "probably lucky" to have suffered only broken nose can be evidence at retrial Larez v. City of Los Angeles, 946 F.2d 630 (9th Cir. 1991).
Award of $950,000 compensatory damages and $500,000 punitive damages for false arrest and assault reduced to $250,000 compensatory and $125,000 punitive where plaintiff suffered "minor scarring" and there was insufficient evidence of loss of earnings Byrd v. NY City Transit Authority, 568 N.Y.S.2d 628 (A.D. 1991).
Punitive damages awarded against individual guard for reckless indifference to safety of inmate beaten and sexually assaulted by cell mate Smith and Wade, 103 S.Ct. 1625 (1983).
Plaintiff sues officer for punitive damages in alleged excessive force suit; punitive damages can not be awarded against a city Miller v. City of Rensselaer, 463 N.Y.S.2d 589 (App. 1983).
Punitive damages must be assessed individually against officers, not jointly McFadden v. Sanchez, 710 F.2d 907 (2nd Cir. 1983).
Possibility of punitive damages does not create conflict of interest requiring separate counsel Galligan v. City of Schenectady, 497 N.Y.S.2d 186 (A.D. 3 Dept 1986).
Punitive damages could be assessed against FBI officials responsible for program designed to disrupt lawful political activities Hobson v. Brennan, 646 F.Supp. 884 (DDC 1986).
Beating of arrestee results in awarding of $100,000 in punitive damages against deputy sheriff; sheriff liable under Louisiana state law (but not federal law). for deputy's actions Hall v. St Helena Parish Sheriff's Dept, 668 F Supp
535 (M.D. La 1987).
Court overturns jury award of punitive damages when officers' conduct was not "sufficiently callous" and no evidence of prior misconduct Odato v. Vargo, 677 F.Supp. 384 (WD Pa 1988).
" See also: Assault and Battery: Flashlights, False Arrest/Imprisonment: Warrant, Firearms Related: Negligent Use, Governmental Liability: Indemnity
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