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HomeMy WebLinkAboutR-93-0083}}; 1/27/93 S RESOLUTION NO. 9 3W 83 4 A RESOLUTION AUTHORIZING THE DIRECTOR OF FINANCE TO PAY TO JAIME ANDRADE, WITHOUT THE ADMISSION OF LIABILITY, THE SUM OF $50,000.00 IN FULL AND COMPLETE SETTLED NT OF ANY AND ALL CLAIMS AND DEMANDS AGAINST THE CITY OF MIAMI, IN CIRCUIT COURT CASE NO. 91-01855 CA (10), UPON THE EXECUTION OF A GENERAL RELEASE RELEASING THE CITY OF MIAMI FROM ANY AND ALL CLAIMS AND DEMANDS, FUNDS TO BE PROVIDED FROM THE INSURANCE AND SELF- INSURANCE TRUST FUND. WHEREAS, Jaime Andrade, through his attorney, filed a claim and lawsuit against the City of Miami in the Circuit Court of Dade County, Florida, Case No. 91-01855 CA (10), for personal injuries and deprivation of civil rights, arising out of an incident involving a City of Miami police officer on September 30, 1988, at N.E. 48th Street and Biscayne Boulevard; and WHEREAS, the above olaim and lawsuit have been investigated by the Torts Division of the City Attorney's Office and the Department of Risk Management pursuant to Ordinance No. 8417, which created the City of Miami's Insurance and Self -Insurance Program, and said Offices at this time recommend that this claim and lawsuit be settled; and WHEREAS, the City Commission deems a settlement in the amount of $50,000.00 to be in the best interest of the City of Miami; cirY COMMSSiON PMTIKG OF FEB 0 9 1993 R"Wutwn No. 93- 83 NOW, THEREFORE, BE IT RESOLVED BY THE COMMISSION OF TUB CITY = OF MIAMI , FLORIDA: Section 1. The Director of Finance is hereby authorized to pay Jaime Andrade, forthwith, without the admission of liability, the sum of $50,000.00 in full and complete settlement of any and all claims and demands against the City of Miami, in Circuit Court Case No. 91-01838 CA (10), upon the execution of a general release, in a form acceptable to the City Attorney, releasing the City of Miami from all claims and demands; said money to be provided from the Insurance and Self--Insuranoe Trust Fund, Account No. 620101-681. Section 2. This Resolution shall become effective immediately upon its adoption. PASSED AND ADOPTED this 9th day of -j bruary . 1993. XAVIE SUAREZ, MAYOR ATT T: FATTY HIRAI CITY CLERK BUDGETARY REVIEW: SELF-INSU CE TRUST FUND REVIEW: MANOHAR S. SURANAjY SUJAN S./bH4BRA, DIRECTOR ASSISTANT CITY WAGER DEPARTMENT -OF RI34.MANA ENT _= PREP ED AND APPROVED BY: APPROVED AS TO FORM AND CORRECTNESS: _A , CHARLES C. MAYS A. QU J S, I i = CHIEF ASSISTANT CITY ATTORNEY CITY ATTO CCM:osk:M3407 _- -2- 93- 83 An CITY OF MIAMI, FLORIDA (;Am INTER-OFFICE MEMORANDUM TO : Honorable Mayor and Members of DATE January 27, 1993 FILE the City Commission FROM: A. inn es City At ney SUBJECT : Resolution Authorizing Settlement with Jaime Andrade, Case No.91-01888 CA (10) REFERENCES City Commission Meeting February 11, 1993 ENCLOSURES ( 2 ` The attaohed proposed resolution authorizes the Direotor of Finanoe to pay Jaime Andrade, without admission of liability, the sum of $50,000.00 in full and oomplete settlement of any and all olaims and demands against the City of Miami, upon exeoution of a Release of All Claims, releasing the City of Miami and its agents, servants, and employees from any and all olaims and demands. The oomplete evaluation of this olaim is contained in the attaohed Tort Committee settlement memorandum. In summary, the olaimant olaims that he was unjustly beaten, arrested and subjeoted to an unwarranted oriminal proseoution by a City of Miami polioe officer whioh oaused him personal injuries, legal expenses, and a deprivation of federally protected rights. This olaim has been investigated by the Tort Committee Ca oopy of the authorization is attaohed), approved by the Risk Management Division, and is hereby reoommended by this offioe. Enos . -;! CCM : osk 93- 83 (1A 11—! CITY OF MIAMI. FLORIDA INTER -OFFICE MEMORANDUM TO: Members of the Tort Committee DATE : January 27, 1993 FILE: L-91-01 SUBJECT FROM :Charles C MaU~ys - REFERENCES Chief .Assistant City Attorney ENCLOSURES: Jaime Andrade v. City of Miami and T. Laura Case No. 91-01855 CA 10 Claim No. 015 f PT-90-018 SETTLEMENT MEMORANDUM On September 30, 1968, the plaintiff, Jaime Andrade, age 50, was notified that his wife had been injured in an automobile accident. Mr. Andrade proceeded to the accident scene, which was being handled by Miami police officer Laura. Mrs. Andrade was trapped inside her automobile and efforts were being made to remove her. Officer Laura indicates that Mr. Andrade became excitable and began to interfere in the effort to free Mrs. Andrade from the car. An altercation ensued between the officer and Mr. Andrade, which culminated in Mr. Andrade being struck in the face by the officer and arrested for assaulting the officer. Mr. .Andrade was transported to jail and released the next day on bond. He engaged an attorney to defend him on the criminal charges, for which he was found not guilty. vi He sued the City and the officer for deprivation of his civil rights pursuant to 42 U.S.C. Section 1983, assault and battery, false arrest, and malicious prosecution (asserted only against the officer). The lawsuit seeks compensatory damages ' against the City and the officer, and punitive damages against the officer. Punitive damages are damages awarded above and beyond compensatory damages. It must be noted that damages awarded under 42 U.S.C. Section 1983 are not subject to the $100,000 limitation on damages as provided for in Section 768.28(5), Florida Statutes; moreover, a successful Section 1983 plaintiff is entitled to recover attorney's fees and costs under y' -42 U.S.C. Section 1988. Mr. Andrade'ss nose was broken as a result of the blow to his fairs, for which he twice received plastic surgery. He also was treated by an optomologist for an injury to his left eye. His medical expenses were approximately $6000.00. Such expenses are recoverable as compensatory damages if liability is established. Members of the Tort Committee Res Jaime Andrade v. City of Miami and T. Laura January 27, 1993 Page 2 Another item of compensatory damages are the expenses associated with the criminal proceedings. He spent $500 to bond out of jail and paid his criminal defense attorney $8,500 to defend him. The $500 is recoverable under the false arrest claim, and the $8,500 is recoverable under the malicious prosecution law. The more significant exposure concerns pain and suffering, and the federal civil rights claim. Liability will be determined on the issue of credibility. it is my considered ,judgment that Mr. Andrade will win the credibility issue. This is so primarily because the incident was witnessed by a Catholic priest who corroborates Mr. Andrade's account that he did not assault the officer; further, the priest has also testified in deposition that Mr. Andrade was not struck once by the officer - as the officer contends - but repeatedly. The photographs taken of Mr. Andrade's facial injuries and the nature of those injuries tend to show that Mr.. Andrade was in - fact struck more than once. In view of the probability of liability being proven by the plaintiff and his entitlement to fixed compensatory damages as set forth above, the uncertainty of the amount of damages for pain and suffering, as well as the absence of any limitation for damages for the civil rights claim (and attorney's fees under 42 U.S.C. Section 1988 for the civil rights damages), it is strongly recommended that this case be settled for $50,000, without any admission of liability. PRO %DISAPPROVED: .17 to(2, f City Arptney )wrren Bittner ,assistant Cit t orney jq - - <� Assistant Cit Att ey Assistant Assis Assistant 1.%.%JLjmy //r- / 93- 83 Members of the Tort Coimnittee Res Jaime Andrade v. City of Miami and T. Laura =_ January 27, 1993 Page 3 David Z. S " r' �C�� heresa L. Girten� Assistant rney Assistant City Attorney Sujan S. Coh4br Director Risk Man&" -m t ment CCM:ra2Ml004