Brewster v. Mills

District Court, N.D. California·Decided November 18, 2022·No. 4:20-cv-03254·Unknown

Opinion

CENIOUS BREWSTER, Case No. 20-cv-03254-HSG

Plaintiff, ORDER RE MOTIONS IN LIMINE v. Re: Dkt. Nos. 121–25, 127–31

DANIEL T MILLS, et al., Defendants.

Before the Court are the parties’ motions in limine, filed October 18, 2022. See Dkt. Nos. 121–25, 127–31. The parties filed oppositions on October 25, 2022. See Dkt. Nos. 135–39, 146–49. The Court held a hearing on November 8, 2022. See Dkt. No. 158. At the hearing, the Court ruled on several motions on the record and directed the parties to file offers of proof regarding the remaining motions. The parties have filed offers of proof and responses. See Dkt. Nos. 163–64, 170–71. The following constitutes the Court’s rulings on the remaining motions. A. Plaintiff’s Motion in Limine No. 2: Criminal and Disciplinary History The Court GRANTS in part, DENIES in part, and DEFERS in part Plaintiff’s Motion in Limine No. 2 per the categories below. Dkt. No. 128. The Court emphasizes that any of the preliminary rulings in this order are subject to reconsideration at trial depending on how the parties present their evidence. With respect to this motion, for example, if Plaintiff opens the door by testifying in a manner contradicted by the excluded records, that may be a basis for admitting them. i. Criminal History Record DENIED for the reasons stated on the record. The convictions fit squarely within the purpose authorized by Federal Rules of Evidence 608 and 609, and Plaintiff sustained each conviction less than ten years ago. See Fed. R. Evid. 608(b), 609(a)–(b). Given the centrality of witness credibility in this case, the probative value of impeachment with these convictions is not substantially outweighed by unfair prejudice or any other Rule 403 consideration. Defendants may thus impeach Plaintiff with these convictions as provided in Rule 609 if he testifies, subject to the standard limiting instruction cabining the purpose for which the jury can consider them. See Ninth Circuit Model Civil Jury Instruction 2.9. Plaintiff submits that if the Court admits this evidence, he would prefer that the information come in via stipulation rather than admission of certified copies of conviction records. See Dkt. No. 171 at 3. That makes sense, and Plaintiff has proposed language the Court finds appropriate. See id.1 The Court DIRECTS the parties to meet and confer and file by November 21, 2022 a trial stipulation tracking Plaintiff’s proposal to be read to the jury. The parties should also prepare a corresponding modified Ninth Circuit Model Civil Jury Instruction 2.9 reflecting this concept, which the Court will read to the jury immediately after the trial stipulation. The limiting instruction should not re-list all of the offenses, and should simply read “The evidence that a witness has been convicted of a felony may be considered . . . .” ii. Booking Cards Defendants state they do not intend to introduce the 2019 booking card unless necessary for impeachment or if Plaintiff opens the door. See Dkt. No. 163 at 3. The Court thus does not need to address the admissibility of the 2019 booking card unless and until it becomes necessary. As to the 2020 booking card, the motion is DENIED, assuming Defendants can properly lay the foundation they proffer in their filings. The 2020 booking card is not hearsay because Defendants do not intend to offer it to prove the truth of the matters asserted. See Fed. R. Evid. 801(c). As Defendants explain, the booking card is being introduced as evidence of what Defendants reviewed and relied on to determine Plaintiff’s housing placement, and to explain how that information informed their later actions. See Dkt. No. 163 at 2–3. This evidence will again be subject to a limiting instruction explaining that the jury is not to consider the card as evidence of the truth of the events described in it, but rather only for the permissible nonhearsay purposes described above. Plaintiff’s arguments about whether Defendants actually relied on the booking card, Dkt. No. 171 at 3-5, go to foundation and may be a basis for cross-examination of defense witnesses, but do not warrant exclusion of the document if an adequate foundation can be laid. iii. Jail Disciplinary History The Court DEFERS ruling to the extent the motion seeks to exclude Plaintiff’s jail disciplinary history. Except for Exhibit 102, it is unclear to the Court whether Defendants intend to offer the records for the truth of the matter asserted. See Dkt. No. 163 at 3–5. The parties also have only sparsely cited any case law on the question of whether the contents of jail disciplinary records are subject to any hearsay exception, or conversely are treated like police reports (which in the Court’s experience are generally treated as hearsay, whether or not they are formally business records at the first level of hearsay analysis). The Court DIRECTS the parties to file simultaneous supplemental briefs of no more than two pages addressing this issue by November 21, 2022. The parties should cite specific authority, preferably from the Supreme Court or the Ninth Circuit, and secondarily from any other court of appeals. The Court will then address this issue with the parties at the further pretrial conference on November 23, 2022. See Dkt. No. 158. iv. Rules Violations Before April 15, 2020 For Exhibits 136 and 137, the Court GRANTS the motion to the extent Defendants offer them as substantive evidence. The violations constitute prohibited propensity evidence under Rule 404(b)(1), and Defendants have not persuasively articulated any permitted purpose under Rule 404(b)(2). Defendants generically recite the 404(b) categories (such as motive, intent, and knowledge), but do not explain how any of them apply, or are relevant. To the extent these documents purportedly show that Plaintiff’s actions “were not inadvertent or a mistake,” Dkt. No. 163 at 6, mistake or inadvertence is not Plaintiff’s theory of the case, and Defendants’ description is essentially no more than an assertion of propensity. Defendants also do not explain how outweighed by the risk of unfair prejudice, confusion of issues, and waste of time that would result from introducing evidence about these other incidents unrelated to the sole retaliation issue remaining in the case. As to the March 24, 2020 incident report, Defendants’ offer of proof suggests that they do not seek to introduce this evidence for its truth, but rather for the nonhearsay purpose of explaining the deputies’ state of mind as it informed their actions. The Court DEFERS ruling on the admissibility of this exhibit under that theory, and needs to discuss the issue in more detail at the further pretrial conference. v. Rules Violations After April 17, 2020 The Court GRANTS the motion as to all violations after April 17, 2020. The violations again constitute prohibited propensity evidence. See Fed. R. Evid. 404(b)(1). Defendants’ argument that the violations tend to show Plaintiff’s behavior from April 15–17 was “not the result of mistake or accident” under Rule 404(b)(2) is unpersuasive, as again there is currently no reason to believe Plaintiff will argue his actions were the result of mistake or accident. B. Plaintiff’s Motion in Limine No. 5: Antigay Harassment, Homophobia, Racism The Court DEFERS ruling on Plaintiff’s Motion in Limine No. 5. Dkt. No. 131. The Court directed Defendants to file an offer of proof regarding this motion. Defendants have not yet done so. The Court will discuss this issue with the parties at the further pretrial conference, and the parties need to be prepared to conclusive

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