Damages

Court’s failure to instruct jury on punitive damages sua sponte did not amount to plain error.

Officer struck plaintiff in face with flashlight and kicked him twice in ribs during traffic stop; injuries included broken nasal bones, fracturing of orbital bone requiring surgery, depression and anxiety, lost profits from contract to rehab homes; expert was not required to prove emotional injuries—“[plaintiff] didn’t need Sigmund Freud to connect his later depression and anxiety to the beating”; jury awarded $3 million in compensatory damages, court of appeals affirms district court’s remittitur to $2 million, holds no inconsistency between remittitur and denial of new trial; punitive da