STEVEN v. RICHARD PART I
Substantial evidence supported finding that defendant police officers were liable for civil rights violation under 42 U.S.C. Sec. 1983 where evidence showed that defendants engaged in, or authorized, a series of law enforcement actions--including traffic stops, equipment compliance citations, and a vehicle impoundment--to retaliate against plaintiff after he complained to CHP management about an officer. Plaintiff did not need to prove that the officers lacked probable cause when they participated in the law enforcement contacts forming the basis for the section 1983 action where plaintiff's claims were not brought on a retaliatory prosecution theory and the claimed damages did not result from criminal charges pursued by a prosecuting agency, and defendants waived issue on remaining claims. Punitive damages awards of $1 million and $3 million against officers were excessive where they would have indisputably resulted in officers' financial ruin.
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