Allianz Life Insurance Company of North America v. Muse

District Court, W.D. Oklahoma·Decided April 11, 2025·No. 5:17-cv-01361·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

ALLIANZ LIFE INSURANCE ) COMPANY OF NORTH AMERICA, ) ) Plaintiff/Counterclaim Defendant, ) ) v. ) Case No. CIV-17-1361-G ) GENE L. MUSE, M.D., ) ) Defendant/Counterclaimant. )

ORDER Now before the Court is a Motion in Limine (Doc. No. 324) filed by Defendant/Counterclaimant Gene L. Muse, M.D. (“Muse”), seeking five in-limine rulings. A response has been filed by Plaintiff/Counterclaim Defendant Allianz Life Insurance Company of North America (“Allianz”) (Doc. No. 333), to which Muse replied (Doc. No. 341). The Court rules as outlined below. I. Applicable Law A motion in limine is a “pretrial request that certain inadmissible evidence not be referred to or offered at trial.” Edens v. The Netherlands Ins. Co., 834 F.3d 1116, 1130 (10th Cir. 2016) (emphasis and internal quotation marks omitted). Through such a motion, a party may “request . . . guidance by the court regarding an evidentiary question, which the court may provide at its discretion to aid the parties in formulating trial strategy.” Id. (internal quotation marks omitted). “A court’s in limine rulings are preliminary and are subject to change as the case unfolds or at its discretion.” Godfrey v. CSAA Fire & Cas. Ins. Co., No. CIV-19-329-JD, 2020 WL 1056306, at *1 (W.D. Okla. Mar. 4, 2020) (citing Luce v. United States, 469 U.S. 38, 41-42 (1984)). II. Defendant/Counterclaimant Muse’s Motion A. Misrepresentation of Facts

Muse first seeks to prohibit Allianz from presenting any evidence or argument that Muse knowingly and intentionally misrepresented relevant facts relating to his health. See Def.’s Mot. at 7-9. In support of this request, Muse argues that Allianz is precluded, under the doctrine of res judicata,1 from presenting such evidence or argument because “the jury in the first trial specifically rejected Allianz’s claims that [Muse] knowingly and

intentionally misrepresented relevant facts relating to his health to Plaintiff.” Id. at 7 (internal quotation marks omitted). Allianz argues that because the current trial is being conducted upon remand of the same case in which a jury previously rejected Allianz’s claims that Muse misrepresented facts relating to his health, “law of the case” not res judicata is the appropriate doctrine under which to consider Muse’s request. See Pl.’s Resp.

at 5-6.2

1 The term “res judicata” “comprises two distinct doctrines regarding the preclusive effect of prior litigation”: The first is issue preclusion (sometimes called collateral estoppel), which precludes a party from relitigating an issue actually decided in a prior case and necessary to the judgment. The second doctrine is claim preclusion (sometimes itself called res judicata). . . . [C]laim preclusion prevents parties from raising issues that could have been raised and decided in a prior action—even if they were not actually litigated. Lucky Brand Dungarees, Inc. v. Marcel Fashions Grp., Inc., 590 U.S. 405, 411 (2020) (citation omitted). 2 “The law of the case doctrine posits that when a court decides upon a rule of law, that decision should continue to govern the same issues in subsequent stages in the same case.” United States v. Monsisvais, 946 F.2d 114, 115 (10th Cir. 1991) (emphasis added) (internal The evidence and argument Muse seeks to exclude are more appropriately considered under the doctrine of issue preclusion (or “collateral estoppel”). “As long as the issues are identical, issue preclusion bars a party from relitigating an issue once it has

suffered an adverse determination on the issue, even if the issue arises when the party is pursuing or defending against a different claim.” Stan Lee Media, Inc. v. Walt Disney Co., 774 F.3d 1292, 1297 (10th Cir. 2014) (internal quotation marks omitted). In the preceding trial, the jury found: (1) by special interrogatory, that Allianz had not proved, by clear and convincing evidence, that Muse had “knowingly and intentionally

misrepresented facts relating to his health to” Allianz; and (2) that Allianz had not proved, by clear and convincing evidence, its claims for (a) fraud and deceit or (b) conspiracy to commit fraud and deceit. See Verdict (Doc. No. 203) at 5, 1; J. (Doc. No. 207) at 1. Neither the special interrogatory response nor the determination of the fraud and conspiracy claims was disturbed on appeal.

In short, Muse invokes the jury’s findings in the prior trial—findings as to which Muse bore no burden of proof (indeed, ones as to which Allianz bore a heavy burden of proof)—to bar evidence and argument in this subsequent trial of a claim for which Muse bears the burden of proof.3 Even if the issue decided in the first trial were otherwise identical to one to be decided in the second trial, a party may not use the doctrine of issue

(“Law of the case rules have developed to maintain consistency and avoid reconsideration of matters once decided during the course of a single continuing lawsuit.” (citation and internal quotation marks omitted)). 3 At the April 10, 2025 pretrial conference, Muse suggested that Allianz may raise fraud or conspiracy to commit fraud as an affirmative defense to Muse’s contract claim. Allianz preclusion to reduce or eliminate its burden of proof. See 18 James Wm. Moore et al., Moore’s Federal Practice § 132.02[4][e] (2021) (“[I]ssue preclusion does not apply when the party seeking to benefit from preclusion has a significantly heavier burden in the

subsequent action than in the prior action.”); Restatement (Second) of Judgments § 28(4) (1982) (same); see also Fears v. Wilkie, 843 F. App’x 256, 261 (Fed. Cir. 2021) (“[I]ssues are not identical if the second action involves application of a different legal standard” than the first action). Accordingly, this request is DENIED.4

B. Muse’s Status as “Chronically Ill” Muse next requests that Allianz should be prohibited from introducing evidence that Muse was not “Chronically Ill” as defined in the Policy. In support of this request, Muse argues that (1) this issue was decided in the former trial, and is thus precluded; and (2) Allianz’s current position, that Muse was not Chronically Ill as defined under the Policy,

is inconsistent with its earlier position that Allianz relied on the truth of Muse’s statements relating to his health to justify payment of benefits. See Def.’s Mot. at 9-10. Allianz responds that the issue in the previous trial actually was “whether there was knowing and intentional fraud committed by Muse such that payments made under the Policy should be returned.” Pl.’s Resp. at 7. Additionally, Allianz argues that its position is not inconsistent

4 To the extent the “law of the case” doctrine applies to the jury’s finding of fact on the issue of Muse’s misrepresentations, the Court’s conclusion remains the same. While the law of the case doctrine applies to conclusions of law, it is questionable whether it applies to findings of fact, as Allianz argues. See Monsisvais, 946 F.2d at 115 n.2 (“We do not address under what circumstances findings of fact become the law of the case”); cf. Entek GRB, LLC v. Stull Ranches, LLC, 840 F.3d 1239, 1242 (10th Cir. 2016) (“[T]he decision because the facts upon which someone is determined to meet the Chronically Ill requirement under the Policy can change. See id.

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Related

Luce v. United States
469 U.S. 38 (Supreme Court, 1984)
United States v. Heriberto Fernandez Monsisvais
946 F.2d 114 (Tenth Circuit, 1991)
Stan Lee Media, Inc. v. Walt Disney Co.
774 F.3d 1292 (Tenth Circuit, 2014)
Edens v. Netherlands Insurance
834 F.3d 1116 (Tenth Circuit, 2016)
Entek GRB, LLC v. Stull Ranches, LLC
840 F.3d 1239 (Tenth Circuit, 2016)