Guptill v. City of Chattanooga

CourtDistrict Court, E.D. Tennessee
DecidedJanuary 23, 2024
Docket1:22-cv-00011
StatusUnknown

This text of Guptill v. City of Chattanooga (Guptill v. City of Chattanooga) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guptill v. City of Chattanooga, (E.D. Tenn. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT CHATTANOOGA

MILES GUPTILL, ) ) Plaintiff, ) ) Case No.: 1:22-cv-11-CLC-CHS v. ) ) Judge Collier CITY OF CHATTANOOGA, and ) OFFICER JOEL GUNN (Individually ) and Official Capacity), ) ) Defendants. )

M E M O R A N D U M

Before the Court is a motion by Plaintiff, Miles Guptill, to strike the affidavit of Ronald Zirk. (Doc. 83.) Defendant City of Chattanooga has responded. (Doc. 87.) This matter is ripe for review. I. BACKGROUND1 Plaintiff, Miles Guptill, filed suit against the City of Chattanooga and Joel Gunn on January 11, 2022. (Doc. 1.) On September 15, 2023, Gunn and the City of Chattanooga filed separate motions for summary judgment against Plaintiff. (Docs. 73 and 76.) Plaintiff responded to both motions on October 20, 2023. (Docs. 81 and 84.) Along with its motion, the City of Chattanooga submitted the affidavit of Ronald Zirk, who is “a Master Instructor” for the Training Division of the Chattanooga Police Department. (Doc. 76-1 at 1.)

1 Here, the Court will limit its discussion to the facts relevant to resolving the motion to strike Officer Zirk’s affidavit. The Court will examine the entire background of the case in resolving the pending motions for summary judgment. On October 20, 2023, Plaintiff moved to strike Officer Zirk’s affidavit. (Doc. 83.) The City of Chattanooga responded on October 27, 2023. (Doc. 87.) This matter is now ripe for review. II. STANDARD OF REVIEW

In ruling on the admissibility of expert opinions, “the trial court has broad discretion . . . .” Brainard v. Amer. Skandia Life Assur. Corp., 432 F.3d 655, 667 (6th Cir. 2005) (quoting Viterbo v. Dow Chem. Co., 826 F.2d 420, 422 (5th Cir. 1987)). Trial courts have held that the power to strike portions of affidavits “which contain nothing more than legal conclusions and speculation without factual support” to be within the mandate of Federal Rule of Civil Procedure 56(e). See King v. Pa. Life Ins. Co., 470 F. App’x 439, 445–46 (6th Cir. 2012); see also Peebles v. A. Schulman Inc., 2006 WL 572337, at *8 (M.D. Tenn, Mar. 7, 2006). III. DISCUSSION A. Federal Rule of Civil Procedure 56 does not warrant striking Officer Zirk’s affidavit.

Plaintiff first argues Officer Zirk’s affidavit should be stricken due to Federal Rule of Civil Procedure 56. (Doc. 83 at 1.) Plaintiff argues that the Court of Appeals for the Sixth Circuit’s guidance in Brainard v. American Skandia Life Assurance Corporation mandates all affidavits be made on personal knowledge and set forth facts that would be admissible in evidence. (Id. at 1.) The City of Chattanooga responds, “Officer Zirk’s affidavit is appropriate and based on his personal knowledge and experience as a training instructor for the Chattanooga Police Department.” (Doc. 87 at 1.) As it relates to Plaintiff’s Brainard argument, the City of Chattanooga responds that the Sixth Circuit’s guidance in King v. Pennsylvania Life Insurance Company should guide this Court instead of Brainard. (Id. at 2–3.) Plaintiff is correct that Federal Rule of Evidence 602 requires witnesses to testify from personal knowledge. However, Rule 602 further states “[t]his rule does not apply to a witness’s expert testimony under Rule 703.” Fed. R. Evid. 602. The Court of Appeals for the Sixth Circuit did examine a trial court’s ability to strike expert

testimony for lack of proper foundation in King. In King, the Court of Appeals reasoned that there is a difference between an expert whose affidavit employs “broad and dramatic language without substance” and contains “no meaningful analysis or reasoning” and one whose affidavit “is “sufficiently reasoned and detailed.” King, 470 F. App’x at 446 (quoting Brainard, 432 F.3d at 664). Here, the Court finds that Officer Zirk’s affidavit is more in line with an affidavit that is “sufficiently reasoned and detailed” than the one at issue in Brainard. Officer Zirk’s affidavit does not merely state conclusions. Instead, he offers his opinion based on his years working with the Chattanooga Police Department and teaching at the Chattanooga Police Academy. Any remaining questions regarding Officer Zirk’s opinions go to his credibility, which is for the trier of fact to

assess. In re Scrap Metal Antitrust Litig., 527 F.3d 517, 529 (6th Cir. 2008). Because Officer Zirk’s affidavit is more than mere speculation and legal conclusions, Plaintiff’s motion to strike Officer Zirk’s affidavit under Federal Rule of Civil Procedure 56 will be DENIED. B. The Federal Rules of Evidence do not warrant striking Officer Zirk’s affidavit.

Federal Rule of Evidence 801 provides that witnesses generally are not allowed to provide testimony that is hearsay. Hearsay is defined as a statement that “(1) the declarant does not make while testifying at the current trial or hearing; and (2) a party offers in evidence to prove the truth of the matter asserted in the statement.” Fed. R. Evid. 801(c)(1)–(2). Plaintiff argues Officer Zirk’s affidavit should be stricken because hearsay evidence “cannot be considered on a motion for summary judgment” under Wiley v. United States, 20 F.3d 222 (6th Cir. 1994). In Wiley, the plaintiff appealed the grant of summary judgment in favor of the United

States. The plaintiff argued the trial court improperly considered an affidavit and certified mailing list that would have constituted inadmissible hearsay at trial. Id. at 225–26. Though the Court of Appeals reasoned that the plaintiff had waived any objection to the inclusion of these documents by not raising the issue at trial, it also stated that “hearsay evidence cannot be considered on a motion for summary judgment.” Id. at 226. The affidavit at issue Wiley is distinguishable from Officer Zirk’s affidavit because the author in Wiley was not purported to be an expert. Instead, he was “an employee in charge of reviewing the notices of deficiency.” Id. at 225. As explained below, this affects the analysis before the Court in determining the admissibility of Officer Zirk’s affidavit. Therefore, the statement by the Court of Appeals in Wiley is not applicable here.

Because the affidavit at issue in the current case was put forth in relation to an expert’s opinion, the Court is guided by Federal Rule of Evidence 703, which provides as follows: An expert may base an opinion on facts or data in the case that the expert has been made aware of or personally observed.

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Guptill v. City of Chattanooga, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guptill-v-city-of-chattanooga-tned-2024.