Deocampo v. Potts

The City of Vallejo petitioned for Chapter 9 bankruptcy in 2008. Two years after the bankruptcy court confirmed Vallejo's debt-adjustment plan, a federal jury found that two police officers employed by Vallejo used constitutionally excessive force when they arrested Jason Eugene Deocampo. The district court entered a judgment for money damages against the officers in their personal capacities, and awarded Deocampo his attorney’s fees. The court noted that, under California law, Vallejo is generally obligated to indemnify its employees for claims against them arising from their employment. The court held that where, as here, the plan confirmed by the bankruptcy court did not expressly encompass claims or judgments against the city’s employees, the indemnification statutes do not subject such claims or judgments to adjustment by operation of law nor by the fact of the public employment itself. The court affirmed the district court’s denial of the officers’ Rule 60 motion for relief from judgment, and agreed with the district court that neither the judgment nor attorney’s fee award was discharged by Vallejo’s bankruptcy proceedings. View "Deocampo v. Potts" on Justia Law