David S. Hutchings v. Tony Mattivi, Director of the Kansas Bureau of Investigation, In His Individual And Official Capacities

District Court, D. Kansas·Decided July 21, 2026·No. 5:24-cv-04080·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

DAVID S. HUTCHINGS,

Plaintiff,

v. Case No. 24-4080-WPJ

TONY MATTIVI, Director of the Kansas Bureau of Investigation, In His Individual And Official Capacities,

Defendant(s).

MEMORANDUM OPINION AND ORDER DENYING MOTION FOR NEW TRIAL THIS MATTER comes before the Court upon Plaintiff’s Motion for a New Trial [Doc. 101] and Memorandum in Support [Doc. 101-1], Defendant’s Response [Doc. 102], and Plaintiff’s Reply [Doc. 103]. From May 18 to May 20, 2026, trial proceeded on Plaintiff David S. Hutchings’ claims against Defendant Tony Mattivi that Plaintiff’s due process rights had been violated when he was allegedly terminated from his position as Associate Director of the Kansas Bureau of Investigation (KBI). On May 20, a petit jury returned a unanimous verdict that Plaintiff David Hutchings voluntarily resigned from his position, and thus, his due process rights were not violated by the Defendant. Docs. 99, 100. In advance of trial, Plaintiff filed an omnibus objection to 22 of 28 exhibits disclosed by Defendant on the grounds of irrelevance or “because their probative value is substantially outweighed by a danger of unfair prejudice or misleading the jury.” Doc. 77 at 1; see Fed. R. Evid. 403. Plaintiff declined to file any motions in limine1 specifying in detail how the probative value of the exhibits in question were outweighed by the danger of unfair prejudice or how the exhibits would be misleading to the jury. Instead, Plaintiff elected to reserve his particularized objections for trial when the exhibits were offered for admission. Plaintiff now asks the Court to grant him a new trial pursuant to Fed. R. Civ. P. 59(a)(1)(A) because, he argues, certain evidence

admitted at trial should have been excluded under Fed. R. Evid. 403. Doc. 101-1 at 1. Defendant opposes. Doc. 102. Upon thorough review of the pleadings and the record, the Court DENIES the Motion for a New Trial. BACKGROUND Trial centered on the conclusion of Plaintiff Hutchings’ appointment as Associate Director of the Kansas Bureau of Investigation (KBI) in July 2023. Plaintiff worked at the KBI beginning in 1990, was promoted to Special Agent in Charge in 2006, and elevated to the position of Associate Director in 2011. Plaintiff alleged that Defendant Mattivi, who was appointed to the position of Director in February 2023, asked Plaintiff to step down so Defendant could appoint a

new Associate Director. According to Plaintiff, he then inquired about obtaining another position within the KBI but Defendant stated that he preferred Plaintiff leave the agency. Although Plaintiff conceded the Associate Director of the KBI serves at the pleasure of the Director, Plaintiff argued

1 On March 6, 2026, the Chief Judge of the Tenth Circuit designated the undersigned judge to preside over the above captioned case as a result of the blanket recusal of all the District Judges in the District of Kansas. At the initial status/scheduling conference conducted by video conferencing technology on March 17, 2026 regarding a new trial date, the Court inquired whether Plaintiff’s counsel intended to file any motions in limine. Plaintiff’s counsel stated that no motions in limine would be filed, and objections to exhibits would be raised at trial. While there is no requirement that Plaintiff’s counsel file motion(s) in limine, the Court asked the question about the potential filing of such motions because the pretrial stage, prior to jury selection, is when lawyers frequently attempt to obtain a pretrial ruling from the trial judge excluding or limiting the jury from seeing or hearing so-called prejudicial evidence offered by the opposing party. While there’s no guarantee a trial judge will rule on the admissibility of evidence argued in a motion in limine at the pretrial stage, to the extent lawyers wish to argue unfair prejudice under Rule 403, a pretrial hearing allows for more extensive written and oral argument by counsel and questioning by the trial judge in contrast to the situation where during a jury trial, counsel make 403 objections that are taken up at a bench conference or when the jury is excused from the courtroom. that Defendant unlawfully terminated not only Plaintiff’s appointment as Associate Director but also his employment with the agency altogether in violation of his right to due process under the Kansas Civil Service Act, K.S.A. § 75-711(c). See Compl., Doc. 1 (Counts I and II). 2 Plaintiff argued that upon his removal, he was entitled to return to a permanent classified position — either as Special Agent in Charge or a comparable position in the classified service. See Doc. 93, at 1–

2. At trial, outside the presence of the jury and over the objection of the Defendant, the Court ruled as a matter of law that § 75-711(c) entitles the appointee to return to a classified position when, as here, the appointing authority asks the appointee to leave the unclassified position. Tr. Vol. III at 92:20–93:21. But because the statutory protections are triggered only upon an involuntary dismissal from the position of Associate Director, see K.S.A. § 75-711(c), the threshold question for the jury was whether Plaintiff was terminated, or instead, whether he voluntarily resigned. See Doc. 98 at 9 (Instruction No. 8); Doc. 99 at 1. It was undisputed that the process required by § 75-711(c) had not been afforded, but that fact was ultimately

inconsequential if the evidence showed that Plaintiff made the voluntary decision to resign. The jury returned a verdict that the Plaintiff voluntarily resigned and was not terminated. Doc. 99. From that determination followed the necessary conclusion that Plaintiff’s due process rights were not violated. In light of its unanimous conclusion on that predicate factual question, the jury did not proceed to consider the remaining questions on the verdict form. Plaintiff Hutchings was the sole witness to testify in support of the Plaintiff’s case in chief. Defense counsel raised no objections to Plaintiff’s testimony, and, opted to question Plaintiff during cross-examination instead of presenting Plaintiff’s testimony during Defendant’s case.

2 The complaint also included a claim for tortious interference, which was voluntarily dismissed prior to trial. See Doc. 81. Several current and former employees of the KBI and a psychologist who conducted an outside report on behalf of the KBI regarding Plaintiff, testified on behalf of the defense. Plaintiff’s counsel raised several objections to the exhibits Defendant offered into evidence, including — as relevant to the instant Motion — on Rule 403 grounds. Those exhibits are discussed further below. LEGAL STANDARD

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David S. Hutchings v. Tony Mattivi, Director of the Kansas Bureau of Investigation, In His Individual And Official Capacities, (D. Kan. 2026).

David S. Hutchings v. Tony Mattivi, Director of the Kansas Bureau of Investigation, In His Individual And Official Capacities (David S. Hutchings v. Tony Mattivi, Director of the Kansas Bureau of Investigation, In His Individual And Official Capacities) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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