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Keywords

defendantdamagestrialcorporationadmissibilityjury instructions

plaintiffdefendantdamagesappealtrialcorporationpunitive damages

Related Cases

Palmetto State Medical Center, Inc. v. Operation Lifeline, 117 F.3d 142, RICO Bus.Disp.Guide 9299

Facts

Palmetto State Medical Center, a South Carolina corporation providing gynecological services including abortions, filed an eight-count complaint against 66 individuals and two anti-abortion organizations, Operation Lifeline and Operation Rescue, after protests occurred at the clinic on three specific dates in 1989. The clinic alleged that the defendants trespassed on its property, blocking patient access. The case involved claims of state-law trespass and civil RICO violations, with the jury initially finding some defendants liable for both.

Plaintiff Palmetto State Medical Center is a South Carolina corporation which provides gynecological services, including abortions, to its patients. Defendants originally were 66 individuals who oppose abortion and two anti-abortion entities, Operation Lifeline and Operation Rescue. On April 28, July 5, and July 8, 1989, anti-abortion protestors demonstrated at the Palmetto clinic.

Issue

The main legal issues included the admissibility of defendants' admissions regarding criminal convictions, the sufficiency of evidence for trespass claims, and whether the defendants engaged in RICO violations.

The Court of Appeals, Widener, Circuit Judge, held that: (1) individual defendants' answers to request for admissions regarding criminal convictions were inadmissible; (2) nontestifying defendants were entitled to judgment as matter of law on trespass claim because only evidence of their participation in protests at issue came from improperly admitted admissions; (3) organization that only distributed literature at protests was not liable for trespass; (4) neither individual defendants nor organization engaged in RICO violation; (5) clinic could not recover damages based on loss of patients absent inquiry into why patients missed their appointments on dates of protests at issue; and (6) defendants were entitled to present evidence of their religious motives on issue of punitive damages.

Rule

The court applied rules regarding the admissibility of evidence, particularly concerning requests for admissions, and the requirements for proving RICO violations, including the need for a pattern of racketeering activity and the establishment of an enterprise.

In South Carolina, '[a]lthough the entry by a person on the property of another may initially be lawful, the person becomes a trespasser when the person fails to depart after being asked by the owner to leave.'

Analysis

The court found that the district court erred in admitting the defendants' answers to requests for admissions regarding their criminal convictions, as these did not establish their involvement in the alleged trespasses at the clinic. The lack of evidence tying the convictions to the specific incidents at issue meant that the trespass claims against many defendants should not have gone to the jury. Additionally, the court determined that the clinic could not recover damages for lost patients without further inquiry into the reasons for missed appointments.

Based on the evidence in the record, the jury could not find that the answers to the requests for admission are probative of plaintiff's claim that defendants trespassed on the plaintiff's property on the dates in question.

Conclusion

The court reversed the judgments against many defendants, vacated others, and remanded the case for new trials, emphasizing the need for proper evidence and jury instructions.

For the foregoing reasons, the trespass judgments against Operation Lifeline, Miss Schell, Miss Vaughn, Brooks, Cloer, Gautsch, and Daniel are vacated and remanded for a new trial consistent with this opinion.

Who won?

The defendants prevailed in part, as the court found significant errors in the district court's handling of evidence and jury instructions, leading to the reversal of judgments against them.

Defendants appeal from judgments against them on state-law trespass and civil RICO claims, assigning numerous errors committed by the district court.

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