DUKE v. DANFREIGHT SYSTEMS, INC.

District Court, S.D. Indiana·Decided March 9, 2022·No. 2:20-cv-00125·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA TERRE HAUTE DIVISION

LAURIE DUKE Jointly and as Natural ) Parents of Morgan Johnson, deceased, ) DALE JOHNSON Jointly and as Natural ) Parents of Morgan Johnson, deceased, ) ) Plaintiffs, ) ) v. ) No. 2:20-cv-00125-JPH-DLP ) DANFREIGHT SYSTEMS, INC., ) PIERRE ST. JEAN, ) ) Defendants. )

ORDER ON MOTIONS IN LIMINE The parties have filed a combined forty-eight motions in limine. A table summarizing the motions and rulings is attached as Appendix A. Consistent with the Court's instructions at the final pretrial conference, counsel shall raise reasonably foreseeable evidentiary issues in advance outside the presence of the jury—generally before or after the trial day, over lunch, or at a break. That includes situations when a party believes that the evidence at trial justifies a modification to this order. To avoid wasting the jury's time, counsel must make every effort to avoid raising reasonably foreseeable issues when they would require a sidebar or recess, which will be allowed only in extenuating circumstances. I. Applicable Law "Motions in limine are well-established devices that streamline trials and settle evidentiary disputes in advance, so that trials are not interrupted mid-

course for the consideration of lengthy and complex evidentiary issues." United States v. Tokash, 282 F.3d 962, 968 (7th Cir. 2002). Still, orders in limine are preliminary and "subject to change when the case unfolds" because actual testimony may differ from a pretrial proffer. Luce v. United States, 469 U.S. 38, 41 (1984). A trial judge does not bind himself by ruling on a motion in limine and "may always change his mind during the course of a trial." Ohler v. United States, 529 U.S. 753, 758 n.3 (2000).

II. Analysis Preliminarily, it is worth noting that the Court and counsel worked through many of the motions in limine over the course of approximately two hours at the final pretrial conference. As emphasized at the conference, the Court expects counsel to stringently adhere to pretrial agreements and orders relating to evidence by careful preparation of their questions and witnesses. To the extent any reference is made to evidence that the Court has ruled inadmissible, the Court will determine whether it was inadvertent or

intentional and proceed accordingly. See Fuery v. City of Chicago, 900 F.3d 450 (7th Cir. 2018). A. Plaintiffs' Motions in Limine 1. Agreement or suggestion that crash was a mere accident or mistake As ordered at the final pretrial conference, this motion is GRANTED in part. Defendants are prohibited from arguing that the crash was nothing more than a "mere accident" or a "simple mistake," but there is not a blanket prohibition on using the word "accident." 2. Argument or suggestion that Pierre St. Jean faced a "sudden emergency" By agreement of the parties, Defendants may not argue that Mr. St. Jean faced a "sudden emergency" at the time of the crash. Dkt. 113 at 2. 3. Suggestion or comment about who pays the verdict By agreement of the parties, Defendants may not make suggestions or comments about who pays the verdict. Dkt. 113 at 3.

4. Suggestion or comment that money will not undo the damage By agreement of the parties, Defendants may not make suggestions or comments that money will not undo the damages from Morgan's death. Dkt. 113 at 3. 5. Evidence of collateral source payments Both parties indicated at the final pretrial conference that they are not aware of and do not intend to introduce evidence of any collateral source payments made to Plaintiffs. For that reason, this motion is Granted. 6. Evidence concerning settlement discussions By agreement of the parties, the parties may not reference or comment about the fact that settlement negotiations took place or the substance of a settlement negotiation. Dkt. 113 at 3; dkt. 108 at 24.

7. Statements suggesting society is overly litigious As ordered at the final pretrial conference, this motion is GRANTED. Defendants are prohibited from arguing that society is overly litigious or that lawsuits like this one contribute to rising insurance rates or inflation. 8. Argument that this is a lawyer-created case or that the lawyers concocted certain damage issues As ordered at the final pretrial conference, this motion is GRANTED. Defendants are prohibited from arguing that this is a "lawyer-created" case or that the lawyers "concocted" certain damage issues. 9. Allegations that Plaintiffs failed to mitigate their damages As ordered at the final pretrial conference, this motion is GRANTED. Defendants are prohibited from arguing that Plaintiffs had a duty to mitigate or that they failed to mitigate their damages. 10. Statements apologizing or expressing concern for Plaintiffs or others for the incident and related damages As ordered at the final pretrial conference, this motion is GRANTED in part. Counsel recognize that a brief acknowledgement of loss may be appropriate and natural when examining the Plaintiffs. What's prohibited by this ruling is counsel making statements apologizing or expressing concern or

sympathy for Plaintiffs to posture or gain favor with the jury. 11. Donations made by others towards funeral or burial costs As ordered at the final pretrial conference, this motion is GRANTED. Defendants are prohibited from providing evidence related to a category of damages that Plaintiffs are not seeking recovery for, including funeral or burial

costs. 12. Plaintiffs' life expectancy shortened by any medical condition This motion is GRANTED in part. The Defendants have not designated an expert to testify at trial and therefore cannot make an argument or offer an opinion regarding a specific life expectancy of either Plaintiff. This does not preclude Defendants from briefly asking Plaintiffs about any known long-term health conditions that a jury could reasonably consider in evaluating damages. 13. Cap on the amount of available damages for loss of love and companionship and prohibition of references to Morgan as an "adult child" As ordered at the final pretrial conference, this motion is GRANTED in part. The parties agreed to refer to Morgan by his age when relevant and are prohibited from referencing or characterizing Morgan as a "child," an "adult," or an "adult child." The purpose of this ruling is to avoid confusing the jury on whether Morgan is a "child" within the meaning of the CWDS. That issue is not disputed because the parties have stipulated to it. This ruling does not preclude the parties from stating that Morgan was Mrs. Duke and Mr. Johnson's child. 14. Automobile crashes involving other family members By agreement of the parties, Defendants may not introduce evidence concerning automobile crashes involving Plaintiffs' family members other than Morgan. Dkt. 113 at 10.

15. Testimony of Danfreight Systems, Inc. (DFS) Corporate Representative and certain phrases and expressions "along the lines" of DFS being "reasonable" or wanting to "do the right thing" As ordered at the final pretrial conference, this motion is GRANTED. While Defendants have indicated they are not calling a DFS Corporate representative at trial, they are prohibited form arguing that DFS is a "reasonable" company, or "wants to the right thing," or any related comments or suggestions. 16. Testimony from Mr. St. Jean By agreement of the parties, Defendants may not call Pierre St. Jean to testify at trial. Dkt. 113 at 10–12. 17.

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DUKE v. DANFREIGHT SYSTEMS, INC., (S.D. Ind. 2022).

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