Eric E. Gofnung v. BMW of North America, LLC

CourtDistrict Court, C.D. California
DecidedMay 4, 2023
Docket2:21-cv-06328
StatusUnknown

This text of Eric E. Gofnung v. BMW of North America, LLC (Eric E. Gofnung v. BMW of North America, LLC) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eric E. Gofnung v. BMW of North America, LLC, (C.D. Cal. 2023).

Opinion

2 O

9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA

11 ERIC GOFNUNG, et al., Case No.: 2:21-cv-06328-MEMF-(JCx) 12 Plaintiffs, ORDER ON DEFENDANTS’ MOTIONS IN 13 v. LIMINE [ECF NOS. 49, 50] AND 14 PLAINTIFF’S MOTIONS IN LIMINE [ECF NOS. 52–58] 15 BMW OF NORTH AMERICA, LLC, 16 Defendant.

21 Before the Court are nine (9) motions in limine filed by Defendant BMW North America, 22 LLC and Plaintiffs Eric Gofnung and Gofnung Chiropractic. For the reasons stated herein, the Court 23 GRANTS the motions in part. 24

26 / / / 27 / / / 28 1 I. Factual Background1 2

3 Plaintiffs are Eric Gofnung and Eric E. Gofnung Chiropractice Co. (collectively,

4 “Gofnung”). Compl. ¶ 3. The instant case is a “lemon law” action, seeking the recovery of damages

5 sustained as a result of Eric Gofnung’s purchase of a 2014 BMW M6 convertible from Defendant

6 BMW North America, LLC (“BMW”). Gofnung seeks pursuant to various provisions of the Song-

7 Beverly Act. See generally Compl.

8 II. Procedural History

9 On August 5, 2021, Gofnung filed a complaint against BMW, alleging six causes of action:

10 (1) violation of California Civil Code section 1793.2(d); (2) violation of California Civil Code

11 section 1793.2(b); (3) violation of California Civil Code section 1793.2(A)(3); (4) breach of express

12 written warranty pursuant to California Civil Code sections 1791.2(a), 1794; (5) breach of the

13 implied warranty of merchantability pursuant to California Civil Code sections 1791.1; 1794;

14 1795.5; and (6) violation of the Magnuson-Moss Warranty Act, 15 U.S.C. § 2301(3). ECF No. 1.

15 The parties engaged in no dispositive motion practice.

16 On March 22, 2023, BMW filed two (2) motions in limine. ECF Nos. 49, 50. Both are

17 opposed. ECF Nos. 69, 70. On the same day, Gofnung filed seven (7) motions in limine. ECF Nos.

18 52–58. BMW filed oppositions to Gofnung’s first and third motions in limine.2 ECF Nos. 59, 60.

19 The Court held oral argument on the motions at the Final Pretrial Conference (“FPTC”) on April 19, 20 2023. 21 22 23 / / / 24 / / / 25 26 27 1 The following factual background is derived from the Complaint. ECF No. 1 (“Compl.”). 2 The Court notes that it appears BMW has misspelled the name of the District Judge presiding over this case 28 in all of its filings. Counsel is advised to ensure that all future filings have the correct caption, including the 1 III. Applicable Law

2 A. Motions in limine

3 A motion in limine is “a procedural mechanism to limit in advance testimony or evidence in a

4 particular area.” United States v. Heller, 551 F.3d 1108, 1111 (9th Cir. 2009). A party files a motion

5 in limine to exclude anticipated prejudicial evidence before the evidence is introduced at trial. See

6 Luce v. United States, 469 U.S. 38, 40 n.2 (1984). A court has the power to grant such motions

7 pursuant to its “inherent authority to manage trials,” even though such rulings are not explicitly

8 authorized by the Federal Rules of Evidence. Id. at 41 n.4 (citation omitted). Regardless of a court’s

9 initial decision on a motion in limine, it may revisit the issue at trial. Id. at 41–42 (“[E]ven if nothing

10 unexpected happens at trial, the district judge is free, in the exercise of sound judicial discretion, to

11 alter a previous in limine ruling.”).

12 B. Federal Rule of Civil Procedure 26

13 Federal Rule of Civil Procedure 26(a)(1) provides that a:

14 party must, without awaiting a discovery request, provide to the other parties: (i) the name and, if known, the address and telephone number of each individual 15 likely to have discoverable information ... that the disclosing party may use to support its claims or defenses, unless the use would be solely for impeachment. 16 . . . 17 (iii) a computation of each category of damages claimed by the disclosing party— 18 who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary mate rial, unless privileged or protected from 19 disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered . . . . 20

21 Rule 26(e)(i) imposes a duty on parties to supplement their Rule 26(a) disclosures if the party 22 learns that its disclosures are incomplete or incorrect. Rule 37(c)(1) gives teeth to these requirements 23 by forbidding the use at trial of any information required to be disclosed by Rule 26(a) that is not 24 properly disclosed. Yeti by Molly, Ltd. v. Deckers Outdoor Corp., 259 F.3d 1101, 1106 (9th Cir. 25 2001). However, the Court provides two exceptions for when the information may still be 26 introduced: if the parties’ failure to disclose the required information is substantially justified or 27 28 1 harmless. Id. (citing FED. R. CIV. P. 37(c)(1)). “Implicit in Rule 37(c)(1) is that the burden is on the

2 party facing sanctions to prove harmlessness.” Yeti, 259 F.3d at 1107.

3 Federal Rule of Civil Procedure 26(a)(1)(A) requires parties to provide initial disclosures to

4 the opposing parties without awaiting a discovery request. The initial disclosures must include a

5 computation of each category of damages claimed by the disclosing party. FED. R. CIV. P.

6 26(a)(1)(A)(iii).

7 While Rule 26 generally requires a party to provide a computation of such damages,

8 emotional damages, because of their vague and unspecific nature, are oftentimes not readily

9 amenable to computation. See Williams v. Trader Publishing Co., 218 F.3d 481, 486 n. 3 (5th Cir.

10 2000) (“Since compensatory damages for emotional distress are necessarily vague and are generally

11 considered a fact issue for the jury, they may not be amenable to the kind of calculation disclosure

12 contemplated by Rule 26(a)(1)(C).”).

13 C. Federal Rule of Civil Procedure 68(b)

14 Federal Rule of Civil Procedure 68(b) provides that “[e]vidence of an unaccepted offer is not

15 admissible except in a proceeding to determine costs.” FED. R. CIV. P. 68(b).

16 D. Federal Rules of Evidence 401 and 402

17 Federal Rule of Evidence 402 explicitly prohibits the inclusion of “irrelevant” evidence. FED.

18 R. EVID. 402. Federal Rule of Evidence 401 prescribes what evidence qualifies as relevant. FED. R.

19 EVID. 401.

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Eric E. Gofnung v. BMW of North America, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-e-gofnung-v-bmw-of-north-america-llc-cacd-2023.