Baldwin v. Union Pacific Railroad Co.

CourtDistrict Court, D. Nebraska
DecidedNovember 9, 2023
Docket8:22-cv-00087
StatusUnknown

This text of Baldwin v. Union Pacific Railroad Co. (Baldwin v. Union Pacific Railroad Co.) is published on Counsel Stack Legal Research, covering District Court, D. Nebraska primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baldwin v. Union Pacific Railroad Co., (D. Neb. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

JOHN C. BALDWIN,

Plaintiff, 8:22CV87

vs. MEMORANDUM AND ORDER UNION PACIFIC RAILROAD CO.,

Defendant.

This matter comes before the Court on the parties’ respective motions in limine. Filing No. 120 (Plaintiff’s motion in limine); Filing No. 123 (Defendant’s motion in limine); Filing No. 132 (Plaintiff’s supplemental motion in limine). The motions are granted in part and denied in part as set forth in greater detail herein. I. BACKGROUND1 Plaintiff, John C. Baldwin, brings suit against his employer, Defendant, Union Pacific Railroad Co., alleging it discriminated against him based on his disability. He alleges disparate treatment and failure to accommodate under the Americans with Disability Act (“ADA”). Filing No. 126 at 3. Union Pacific asserts defenses of direct threat, business necessity, and good faith. Id. The case is set for trial on November 13, 2023. Baldwin has filed nine motions in limine. See Filing No. 120; Filing No. 132. Union Pacific has filed thirteen. Filing No. 123. The Court will address the parties’ arguments in turn.

1 A more extensive background can be found in the Court’s ruling on summary judgment, Filing No. 119. II. ANALYSIS A. Standard of Review Although the motion in limine is an important tool available to the trial judge to ensure the expeditious and evenhanded management of the trial proceedings, performing a gatekeeping function and sharpening the focus for later trial proceedings, some evidentiary submissions cannot be evaluated accurately or sufficiently by the trial judge in such a procedural environment. Jonasson v. Lutheran Child & Fam. Servs., 115 F.3d

436, 440 (7th Cir. 1997). A motion in limine is appropriate for “evidentiary submissions that clearly ought not be presented to the jury because they clearly would be inadmissible for any purpose.” Id. In other instances, it is necessary to defer ruling until during trial, when the trial judge can better estimate the impact of the evidence on the jury. Id. Courts are guided by Federal Rules of Evidence 401 and 403 in resolving these motions. A court must evaluate whether the proposed evidence is relevant in that it has “any tendency to make a fact more or less probable than it would be without the evidence” and whether “the fact is of consequence in determining the action.” Fed. R. Evid. 401. Even if the evidence is relevant, a court may preclude it if “its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice,

confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.” Fed. R. Evid. 403 B. Baldwin’s Request to Sequester Witnesses Baldwin moves to sequester the witnesses at trial. Filing No. 121 at 6. Union Pacific does not oppose this request. Filing No. 139 at 1. “At a party’s request, the court must order witnesses excluded so that they cannot hear other witnesses’ testimony.” Fed. R. Evid. 615. Accordingly, the Court grants Baldwin’s motion to sequester. Baldwin, as the plaintiff, and Union Pacific’s corporate representative, are excluded from the sequestration order. C. Baldwin’s Request to Exclude or Limit Train-Accident Testimony Baldwin asks the Court to exclude evidence regarding any train accidents. Filing No. 121 at 6. He argues that in previous cases, Union Pacific has attempted to introduce evidence of train accidents in Oklahoma and Nevada, presumably relating to safety issues, but that such evidence is irrelevant and unfairly prejudicial. Union Pacific states

it does not intend to affirmatively introduce evidence of any past train accidents in this case. Filing No. 139 at 1–2. However, it cautions that if Baldwin introduces evidence that makes train accident evidence necessary, it may wish to introduce such evidence in rebuttal. The Court thus grants Baldwin’s motion to preclude Union Pacific from introducing evidence of train accidents in its case in chief. Should Union Pacific decide it needs to introduce such evidence in rebuttal, it should bring the issue to the Court’s attention, out of earshot of the jury, so that the Court can decide any relevance and 403 objections to the specific evidence that is proposed at that time. D. To Exclude or Limit Evidence About Baldwin’s Application for Railroad Retirement Board Benefits

Baldwin initially asks the Court to exclude evidence that he applied for and received Railroad Retirement Board (“RRB”) benefits. Filing No. 121 at 8. However, in his reply brief, he withdraws his objection to Defendant’s RRB-related exhibits and instead proposes a limiting jury instruction. The Court will accordingly consider giving such a limiting instruction and will solicit the parties’ input at the instructions conference. However, Plaintiff still objects to Union Pacific intending to introduce Dr. Heather Phipps’s report into evidence. Dr. Phipps is a medical partner to Baldwin’s treating orthopedic surgeon, Dr. David Fischer, and she evaluated Baldwin in conjunction with his RRB application in May 2018. Neither party proposes calling Dr. Phipps at trial, and the parties expect to have Dr. Fischer’s designated deposition testimony serve as his trial testimony. During his deposition, Dr. Fischer indicated he had not seen Dr. Phipps’s report before and did not know how or when it was created. See Filing No. 158-1. Union Pacific contends Dr. Phipps’s report should be admissible as a business-records exception to hearsay, but it

does not appear any witness is able to lay foundation to support that contention. Accordingly, while the parties will be permitted to discuss RRB benefits as they are relevant to Baldwin’s entitlement to back pay, Dr. Phipps’s report is not admissible. E. The Parties’ Conflicting Requests Regarding In-Person Medical Exams Both parties file motions in limine regarding the necessity of an in-person medical exam for fitness-for-duty purposes under the ADA. The ADA prohibits an employer from requiring a medical examination or inquiring into the disability status of an employee “unless such examination or inquiry is shown to be job-related and consistent with business necessity.” 42 U.S.C. § 12112(d)(4)(A). However, “[a] covered entity may make inquiries into the ability of an employee to perform

job-related functions.” 42 U.S.C. § 12112(d)(4)(B); accord Thomas v. Corwin, 483 F.3d 516, 527 (8th Cir. 2007) (“[C]ourts will readily find a business necessity if an employer can demonstrate . . . a medical examination or inquiry is necessary to determine . . . whether the employee can perform job-related duties when the employer can identify legitimate, non-discriminatory reasons to doubt the employee's capacity to perform his or her duties . . . .” (quoting Conroy v. N.Y. State Dep’t of Corr. Servs., 333 F.3d 88, 98 (2d Cir. 2003))). A fitness-for-duty evaluation falls into this category. Similarly, the ADA permits employers to “include a requirement that an individual shall not pose a direct threat to the health or safety of other individuals in the workplace.” See 42 U.S.C. § 12113(b).

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Baldwin v. Union Pacific Railroad Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/baldwin-v-union-pacific-railroad-co-ned-2023.