HomeMy WebLinkAboutR-92-0015C
J-92-41
12/17/91
RESOLUTION NO. 9 2 +- -I. 5
A RESOLUTION AUTHORIZING THE DIRECTOR OF
FINANCE TO PAY TO LEONEL DIAZ LEON AND
DOLORES LEON, WITHOUT THE ADMISSION OF
1 LIABILITY, THE SUM OF $50,000.00 IN FULL AND
COMPLETE SETTLEMENT OF ANY AND ALL CLAIMS AND
DEMANDS AGAINST THE CITY OF MIAMI AND OFFICER
TOM LAURA, IN CIRCUIT COURT CASE NO. 89-7343
(CA 27), UPON THE EXECUTION OF A GENERAL
' RELEASE RELEASING THE CITY OF MIAMI AND
OFFICER TOM LAURA FROM ANY AND ALL CLAIMS AND
DEMANDS, FUNDS TO BE PROVIDED FROM THE
INSURANCE AND SELF-INSURANCE TRUST FUND.
WHEREAS, Leonel Diaz Leon and Dolores Leon, through their
attorneys, filed a claim and lawsuit against the City of Miami
and Officer Tom Laura, in the Circuit Court of Dade County,
Florida, Case No. 89-7343 (CA 27), for alleged assault and
,t
battery, malicious prosecution, violation of civil rights and
-:i loss of consortium, arising out of an automobile stop involving
an off -duty City of Miami police officer, Tom Laura, on
February 28, 1987, at or near Interstate 195 near North Miami
_ k Avenue, Miami, Dade County, Florida, and
WHEREAS, the above claim and lawsuit has been investigated
l
by the Torts Division .of the City Attorney 's Office and the
4 Office of Risk Management pursuant to Ordinance No. 8417, which
created the City of Miami's Insurance and Self -Insurance Program
l
and said Office recommends that this claim and lawsuit be settled
s.
for the sum of $50,000.00;
i NOW, THEREFORE, BE IT RESOLVED BY THE COMMISSION OF THE CITY
OF MIAMI, FLORIDA:
f
j Section 1. The Director of Finance is hereby authorized to
pay Leonel Diaz Leon and Dolores Leon, his wife, forthwith,
I
without the admission of liability, the sum of $50,000.00 in full
Iand complete settlement of any and all claims and demands against
i
the City of Miami and Officer Tom Laura, in Circuit Court Case
No. 89-7343 (CA 27), upon the execution of a general release in a
form acceptable to the City Attorney, releasing the City of Miami
and Officer Tom Laura from all claims and demands; said money to
be provided from the Insurance and Self -Insurance Trust Fund.
Section 2. This Resolution shall
immediately upon its adoption.
PASSED AND ADOPTED this 9th
i
SELF-INSURANCE UST FUND REVIEW:
3
SUJAN CHHA , DIR CTOR
OFFICE OF ISK GEMENT
n
r,
day of Ja
become effective
XAVIER L
, 1992.
-2- 9 2 -- 15
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BUDGETARY REVIEW:
MANOHAR S. SURANA
ASSISTANT CITY MAN ER
PREPARED AND .APPROVED BY:
EN BITTNER
STANT CITY ATTORNEY
APPROVED AS TO FORM AND CORRECTNESS:
A. • QU NN E , I I I
CITY ATT EY
WB/sls/M2703
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CITY OF MIAMI, FLORIDA
INTER -OFFICE MEMORANDUM
� CA- = 15
J-92-41
TO Honorable Mayor and Members DATE December 17, 1991 FILE. L-89-045
of the City Commission
SUBJECT Resolution Authorizing
Settlement with Leon
Case No. 89-7343 (CA 27)
cROM A. uinn nes, III,. `U REFERENCES
City At ney City Commission Agenda
ENCLOSURES. January 9, 1992
(2)
Attached is a proposed Resolution authorizing the Director of
Finance to pay Leonel Diaz Leon and Dolores Leon, his wife,
without 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 and Officer Thomas Laura, upon the execution of a
General Release of All Claims, releasing the City of Miami and
Officer Thomas Laura from any and all claims and demands.
The complete evaluation of this claim is contained in the attached
Tort Committee settlement memorandum. In brief, the claimant
sustained injuries in an incident with a City of Miami police
officer, in which the officer is alleged to have used excessive
force in extricating plaintiff from his automobile.
This claim has been investigated by the Tort Committee and the
Office of Risk Management, and is hereby recommended by this
Office.
AQJ/WB/sls/P1248
attachments
92- 15
CA /S -1
i Irk.
CITY OF MIAMI, FLORIDA
INTER -OFFICE MEMORANDUM
TO Members of the Tort Committee DATE December 4, 1991 FILE L-89-045
SUa,ECT Leonel Leon vs. City &
Officer Tom Laura
' D/I: February 28, 1987
FROM Warren Bittner �-r -�-_, REFERENCES Miami, Florida
Assistant City..etorney Claim #015/PT-88-125
ENCLOSURES
REQUEST FOR SETTLEMENT AUTHORITY
AND AUTHORITY TO PROCEED TO TRIAL
STATUS
This case is presently set for trial beginning the two -week period
commencing December 9, 1991. The case will be going to mediation
this Thursday, December 5, 1991.
FACTS:
On February 28, 1987, at approximately 4:30 p.m., Officer Tom
Laura, while off -duty driving his private vehicle, but in full
uniform and on his way to an off -duty job at Bayside, was driving
southbound on I-95. At about 79th Street, a large van in front of
and to the left of Officer Laura erratically swerved and hit
Officer Laura's vehicle on the left front bumper smashing a light.
The van then swerved back the other way striking Officer Laura's
vehicle on the right side. Officer Laura accelerated alongside
the van's right side and motioned to the driver (the plaintiff) to
pull over. The plaintiff, sighting the officer, "stepped -on -it"
and "took -off" down I-95 at a high rate of speed. Officer Laura
requested assistance via his police radio advising of a hit and
run driver. At the junction of I-195 (Julia Tuttle Causeway going
east to the beach) and SR 112 (going west to the airport), the
plaintiff swerved across several lanes of traffic and exited onto
I-195 in an unsuccessful attempt to lose Officer Laura.
Officers Mosher and Tuttle, hearing that the hit and run driver
had exited I-95 at I-195 going east, proceeded to come to Officer
Laura's assistance. Officer Mosher entered I-195 eastbound from
Miami Avenue, placed himself in front of traffic, and stopped and
blocked traffic. Officer Tuttle had entered I-195 at Miami Avenue
going westbound and observed plaintiff's van entering I-195
- eastbound from the I-95/I-195 overpass. When Officer Tuttle saw
the van he recalls it becoming "boxed -in" by police cars; one in
front, one on the side and one in back, which forced plaintiff's
• vehicle to come to a stop.
f-)
Members of the Tort Committee December 4, 1991
Page Two
Officer Laura, parking alongside of and to the rear of the van in
a traffic lane, exited his private vehicle and approached the van
from the rear together with Officer Tuttle. Upon reaching the
van, Officer Laura opened the door and told Plaintiff to get out.
The plaintiff was reportedly belligerent and was yelling something
to Officer Laura in Spanish when Officer Mosher approached too.
Each officer testified they believed plaintiff was under the
influence based upon a distinct odor of alcohol, plaintiff's blood
shot eyes, his slurred speech and his violent demeanor.
As Officer Tuttle withdrew to move Officer Laura's car out of
traffic, Officer Mosher witnessed Officer Laura being kicked in
the chest by the plaintiff. Officer Laura then grabbed
plaintiff's left arm with both hands to pull him out of the van,
upon which plaintiff threw a punch at Officer Laura with his right
fist which struck him on the top of his head. Officer Laura then
struck the plaintiff in the face (probably more than once) with
his right fist and pulled plaintiff out of the car. Plaintiff
landed on his back in the roadway. Officer Laura handcuffed
plaintiff's left arm, and Officer Mosher the right, after which no
further force was used.
While waiting for a transporting unit to arrive, and while
plaintiff was seated (handcuffed) on the rear bumper of the van,
he jumped up and kicked a glass containing what his wife later
admitted was a glass of whiskey and Pepsi Cola. Plaintiff has
testified that he routinely drinks for his circulation per
"doctor's orders".
A short time later, the transporting Officers, Gil and Lopez,
arrived and plaintiff was placed in the back of their patrol car
for transport to Ward D. Plaintiff resisted getting in the car.
Officer Gil related that plaintiff appeared "upset, sweating and
had an odor of alcohol on hia breath".
Immediately thereafter, Sgt. Jeff Turner responded to the scene
reference a control of persons report. Plaintiff was already
subdued, handcuffed and seated in the back seat of the marked unit
when he arrived. Sgt. Turner related that plaintiff "reeked of
alcohol" and was slightly incoherent. Sgt. Turner determined that
Officer Laura had conducted himself within departmental
guidelines.
Plaintiff was charged with: (1) battery upon a police
officer; (2) DUI; (3) leaving the scene of an accident; (4)
resisting with violence; and (5) careless driving.
92` 15
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AWA
Members of the Tort Committee
December 4, 1991
Page Three
SUBSEQUENT CRIMINAL PROSECUTION:
1. Battery on a Police Officer - After several continuances were
requested by the defendant (Leonel Leon), the charge of
battery on a police officer was dismissed for lack of
prosecution (all officers except Officer Laura showed up and
the Court denied the State's motion for continuance).
Officer Laura had appeared three times before.
2. Resisting Arrest with Violence - No action was taken by the
State Attorney on the charge of resisting with violence.
3. puS - This charge was DDI grossed by the State Attorney
because the plaintiff's blood analysis came back .09 and
there was no video to otherwise establish the charge.
4. Leaving the Scene of the Accident - On this charge the
accused was found nal guilty.
5. Careless Driving - On this charge the accused would found
guilty.
As the photographs of plaintiff show, plaintiff sustained
numerous facial bruises of the face and back as well as
bruises, scrapes and "road burns" of his left arm, shoulder
and leg.
Plaintiff claims that he sustained a fracture of the left
elbow and a trauma injury to his back at the time.
Although x-rays taken at Jackson Memorial Hospital's Ward D
were negative for fractures or dislocations, x-rays
subsequently taken by Dr. Pedro Alonso at Cedars were read by
him to indicate a fracture of the left elbow, i.e., a
fracture of olecranon process. Dr. Alonso applied a cast for
90 days.
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Members of the Tort Committee
December 4, 1991
Page Four
Plaintiff was also treated by Dr. Rigoberto Padilla for pain
in his low back. 1,7he plaintiff suffered from a pre-existing
spondylolisthesis secondary to osteoarthritic changes at
L4-L5, which he claims is now aggravated. Plaintiff first
saw Dr. Padilla on November 11 1982 (almost 5 years pre -
incident), where he was repeatedly treated for his low back
complaints. Dr. Padilla suggested he wear a girdle
permanently at that time. He discontinued treatment in May
of 1985 (about two years before the incident) until May of
1989, when Dr. Padilla took x-rays and saw the patient one
time concerning his back problem.
Dr. Neal performed an IME on plaintiff for these problems on
November 13, 1990, and concluded that he had no permanent
impairment in accordance with the American Medical
Association's Guide for Permanent Impairment.
For these miscellaneous problems, directly related to the
incident, plaintiff accumulated medical bills in the amount
of $2,765.40.
B. LEFT FOOT
On March 30, 1990, over three years following the incident at
issue in this case, plaintiff sought treatment from Dr. Alan
Shader, a podiatrist. He complained of pain and swelling in
the left foot which he claimed he has had for over 2 years.
Dr. Shader localized the pain at the plantar aspect of the
1st metatarsal and diagnosed a bone infection. Dr. Shader
found an ulcerative lesion under the 1st metatarsal which
plaintiff indicated was present for 2 days. The ulcer was
caused by a metatarsal plantar flexion (the 1st metatarsal
was lower than the rest). Surgeries were performed on
4/12/90, 5/11/90, 7/13/90 and 7/20/90 to remove infected
bone. During his deposition, Dr. Shader indicated that one
possible cause of a metatarsal flexion could be trauma and
that the trauma could have occurred years earlier.
Finally, plaintiff sought the advice of an orthopedic
surgeon, Dr. John Bowker, of the University of Miami, who
performed the last surgery on January 22, 1991, which was
successful. Dr. Bowker noted on March 18, 1991, that the
plaintiff had virtually no pain in the left foot at that
time.
-11 Spondylolisthesis: forward displacement of a lumbar vertebra
on the one below it producing pain by compression of the nerve
roots.
92-- 15
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Members of the Tort Committee December 4, 1991
Page Five
When later examined by Dr. Neal for a 2nd IME, specifically
for the foot, on May 29, 1991, plaintiff complained of almost
constant pain and numbness in his left foot. Dr. Neal
concluded that the plaintiff had a 15% permanent disability
of the left foot secondary to infection and gout, but did not
feel that the left foot complaints were related to the
incident.
Plaintiff's medicals for the foot are $78,362.29.
Plaintiffs' present demand is for $107,500.00, which is
inclusive of the wife's loss of consortium claim. Plaintiff
has claims against the City for excessive force, and for
assault and battery only. Against Officer Laura
individually, plaintiff, Leonel Leon, has claims for
violation of civil rights under Section 1983, excessive
force, assault and battery, and malicious prosecution. Loss
of consortium claims by the wife are lodged against both
defendants.
Our chief witness, Officer Tom.Laura, is presently relieved
of duty, pending a criminal charge of perjury arising out of
an unrelated and subsequent alleged police brutality case.
Plaintiffs' counsel is seeking to introduce this incident
into evidence to show similar conduct on the part of Officer
Laura. My efforts to resist plaintiffs' discovery into this
incident met with deaf ears before Judge Capua, the presiding
judge. I believe he will allow this incident into evidence,
even though it will severely prejudice the defendants. The
trial on Officer Laura's criminal prosecution is presently
set for February 11, 1992.
Based upon the facts of Officer Laura's present status and
the almost shocking photographs of plaintiff, Leonel Leon, I
believe that an offer of up to $50,000.00 should be made in
this case. I do not believe that plaintiff's association of
his foot injury to this incident is wholly realistic and
opposing counsel recognizes the severe causation problem.
9 2 i--
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Members of the Tort Committee
December 4, 1991
Page Six
Nevertheless, if the jury finds a violation of civil rights
through excessive force, which I believe they will, plaintiff
will also be entitled to attorney's fees, which will be
significant since we have deposed numerous doctors, witnesses
and prepared for trial at least twice in the past.
APPROVED/DISAPPROVED - Settlement of up to $50,000.00.
KA Q NN JONE , III
City Attorney
RAFAEL O. DIAZ
Deputy City Attor'Rey
CHARLE . MAYS
Chief As istant City Attorney
M. FIRTE
sistant City Attorney
CHRISTOPHER F. R RTZ
Assistant City ttorney
Assistant City Attorney
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V -6
THERESA L. GIRTEN
Assistant City Attorney
MICHAEL MISLER
Liability Supervisor