Background
Garry Richardson sued Sergeant Mike Jackson and the City of Detroit under Section nineteen eighty-three of Title forty-two of the United States Code, alleging excessive force and battery. The incident occurred in September two thousand and nineteen when Sergeant Jackson observed Richardson parking partially in a crosswalk. Richardson claimed the officer lifted and threw him to the ground, causing back injuries, while the officer testified that Richardson went limp and fell on his own during an attempted arrest for driving without a license. A jury returned a verdict for the defendant, and the district court denied Richardson’s motion for a new trial.
The court’s reasoning
The Sixth Circuit reviewed the denial of the new trial motion for abuse of discretion. The court found that the case turned on credibility, and the jury was not unreasonable in believing the officer’s version of events. The court held that the number of witnesses does not control the weight of evidence. Regarding the late disclosure of Officer Taylor, the court found the district court cured any prejudice by postponing the trial and allowing a deposition. The court also affirmed the admission of booking records and Michigan statutes, noting they were relevant to the lawfulness of the arrest and Richardson’s injury claims. Finally, the court found that defense counsel’s comments about a lottery ticket did not warrant a new trial given the jury instructions and lack of objection to the second comment.
We do not believe that they did so unreasonably, let alone that the district court abused its discretion in concluding as much.
Richardson v. City of Detroit, No. 25-1493 (6th Cir. Jul. 01, 2026)
What it means going forward
The decision reinforces that appellate courts will not substitute their judgment for a jury’s credibility determinations in excessive force cases where evidence is conflicting. It also clarifies that district courts have broad discretion to manage discovery violations by postponing trial rather than excluding witnesses, provided the opposing party is given an opportunity to depose the late witness.