LOS ANGELES (LN) — U.S. District Judge Christina Snyder on Dec. 22 denied a motion for a new trial and reconsideration in a case involving a cannabis licensing scheme, ruling that the City of Baldwin Park and former officials did not warrant relief after a jury found fraud and negligence.
The court had previously granted partial judgment as a matter of law, wiping out the jury’s $0.29 million negligence verdict against the City and vacating the fraud verdicts against former City Council member Ricardo Pacheco and former Mayor Manuel Lozano.
The jury’s remaining $1.6 million fraud verdict against former City Attorney Robert Tafoya stood.
Plaintiffs DJCBP Corporation d/b/a Tier One Consulting and David Ju argued that the court erred in excluding Tafoya and Pacheco’s plea agreements and felony convictions, which detailed bribery and development deal schemes.
The court found the exclusion was proper under Federal Rule of Evidence 403, noting the plea deals were lengthy, contained irrelevant allegations of unrelated criminal conduct, and risked confusing the jury.
On the motion for prejudgment interest, the court granted plaintiffs’ request for 7 percent interest on $1.19 million, starting March 23, 2021, noting the defendants failed to file a timely opposition.
The court denied plaintiffs’ motion for attorneys’ fees, finding they had not yet established an independent basis for recovery on tort claims and that the contractual fee provision did not automatically cover all litigation.
The court reserved the issue of reasonableness of fees and costs for a later determination.
Defendants’ motion for sanctions and fees was also denied without prejudice, as the court found no basis for inherent power sanctions or Section 1927 sanctions at this stage.
The case highlights the complex interplay between criminal convictions and civil liability in municipal corruption cases, where evidentiary rulings can significantly impact the scope of a jury’s verdict.