Johnson v. Rush Enterprises, Inc.

CourtDistrict Court, E.D. California
DecidedDecember 9, 2024
Docket1:19-cv-00105
StatusUnknown

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

Bluebook
Johnson v. Rush Enterprises, Inc., (E.D. Cal. 2024).

Opinion

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10

11 WILLIAM LEE JOHNSON, et al., Case No. 1:19-cv-00105-SAB

12 Plaintiffs, ORDER RE AMENDMENT TO PRETRIAL ORDER; PRETRIAL PROCEDURES; 13 v. ALLOWING LIMITED TESTIMONY BY VIDEOCONFERENCE AND USE OF 14 NATURAL GAS FUEL SYSTEMS, INC. INDEPENDENT COURT REPORTER FOR D.B.A. MOMENTUM FUEL PREPARATION OF UNOFFICIAL 15 TECHNOLOGY, et al., TRANSCRIPT

16 Defendants. (ECF No. 165)

17 18 A. Trial Briefs 19 In the amended pretrial order (ECF No. 165), the Court permitted that trial briefs were 20 optional. However, the Court amends its pretrial order to require that each party file a trial brief 21 no later than January 9, 2025. The form and content of the trial brief must comply with Local 22 Rule 285. Special attention shall be given in the trial brief to address reasonably anticipated 23 disputes concerning the substantive law, jury instructions and/or admissibility of evidence. L.R. 24 285(a)(3). The parties need not include in the trial brief any issue that is adequately addressed in 25 a motion in limine or in an opposition brief to a motion in limine. 26 B. Jury Selection 27 Plaintiffs William and Joan Johnson; Intervenor Plaintiff Markel; Defendant Momentum; 1 dire the jury. The time limitation will be strictly enforced. 2 In a civil action, each party is entitled to three peremptory challenges. 28 U.S.C. § 1870. 3 “Several defendants or several plaintiffs may be considered as a single party for the purposes of 4 making challenges, or the court may allow additional peremptory challenges and permit them to 5 be exercised separately or jointly.” Id. Section 1870 “prescribes only the number of peremptory 6 challenges to which each [p]arty is entitled. It specifically leaves to the trial court's discretion the 7 number and manner of exercise of peremptories in cases where there are ‘(s)everal defendants or 8 several plaintiffs.’ ” Carr v. Watts, 597 F.2d 830, 832 (2d Cir. 1979) (quoting 28 U.S.C. § 9 1870); compare Meza-Perez v. Sbarro LLC, No. 23-15702, 2024 WL 4532903, at *5 (9th Cir. 10 Oct. 21, 2024)1 (finding the district court did not abuse its discretion in treating defendants, 11 which were represented by different counsel and subject to different claims requiring different 12 defenses, as different parties and granting each party three peremptory challenges); Nehring v. 13 Empresa Lineas Maritimas Argentinas, 401 F.2d 767 (5th Cir. 1968) (finding the district court 14 did not abuse its discretion in refusing “to equalize the peremptory challenges, i.e.. to give the 15 [plaintiff] the same number of peremptory challenges” that the defendant and impleaded third 16 party were each allowed, ultimately determining an imbalance of three peremptories by the 17 plaintiff, three peremptories by defendant, and three peremptories by the impleaded party was 18 not an abuse of discretion), with Moore v. S. Afr. Marine Corp., 469 F.2d 280, 281 (5th Cir. 19 1972) (finding no error in the district court's requirement that two co-defendants—one which 20 filed a third party complaint for indemnity against the other—share the same number of 21 peremptory challenges allowed to plaintiff) and Rogers v. De Vries & Co., 236 F. Supp. 110, 111 22 (S.D. Tex. 1964) (“Under [28 U.S.C. § 1870] it was within the discretion of the Court to allow 23 three peremptory challenges to the Plaintiff and either allow a total of three to both defendants, 24 or three to each defendant to be exercised separately or jointly”). 25 The Court has considered the parties’ respective positions, claims, and crossclaims and 26 finds it appropriate to treat Plaintiffs and the Intervenor Plaintiff as a single party, and 27 1 Momentum, Pape, and Carleton as a single party. See 28 U.S.C. § 1870. Due to the number of 2 plaintiffs and defendants, the Court will increase the number of peremptories per side by three 3 challenges. In other words, the two Johnson plaintiffs and the Intervenor Plaintiff are entitled to 4 six peremptory challenges to be exercised jointly. The Court finds Defendants, which are each 5 subject to the same claims by Plaintiffs and the Intervenor Plaintiff, are also entitled to six 6 peremptory challenges. However, because Defendants Momentum, Pape, and Carleton assert 7 different crossclaims against each other and each have different defenses to those claims, the 8 Court shall divide the six peremptories equally between the Defendants. Thus, the Court will 9 designate two peremptory challenges for Momentum, two peremptory challenges for Pape, and 10 two peremptory challenges for Carleton. Defendants may exercise their two peremptory 11 challenges separately or some or all Defendants may exercise their challenges jointly without 12 court intervention. Should any party file objections to the number of peremptory challenges, 13 such objections must include an alternate proposal with appropriate legal authority. Any party 14 opposing those objections and/or alternative shall have three days to respond. 15 C. Bifurcation 16 During October 2024 status conferences, it appeared to the Court that the parties agreed 17 the action was essentially an admitted liability case and the only issues remaining were 18 Plaintiffs’ damages and Defendants’ apportionment of fault. It was the Court’s understanding 19 that the parties agreed liability would be stipulated and that the trial would be bifurcated into two 20 phases: one phase for Plaintiffs’ damages and a second phase for apportionment of fault amongst 21 Defendants. On November 21, 2024, the Court ordered that the parties file a joint statement 22 confirming the parties’ agreement to bifurcate the trial and the division of phases. (ECF No. 23 196.) 24 On November 27, 2024, the parties filed a joint statement regarding bifurcation 25 representing that the parties agreed that the trial should be bifurcated. (ECF No. 199.) However, 26 the parties proffered the division of phases should be as follows: (1) Damages, then (2) “Liability 27 and Apportionment Issues.” (Id. at 2.) As discussed at the December 4, 2024 hearing, the Court 1 Instead, the Court finds that a bifurcated trial performed in the phases proposed by the parties 2 would confuse the jury, necessarily require cumulative evidence be presented, and extend rather 3 than streamline the trial. Without objection at the December 4, 2024 hearing, the Court informed 4 the parties that the trial would not be bifurcated. Trial shall proceed in a single phase and all 5 aspects of the case, including liability, damages, crossclaims, and allocation of fault, will be 6 presented and decided in one continuous proceeding. 7 As proposed by the parties at the December 4, 2024 hearing, the presentation of the 8 evidence in the single-phased trial shall be as follows: Plaintiffs William and Joan Johnson and 9 Intervenor Plaintiff Markel shall present their cases-in-chief; Defendant Momentum will present 10 its defense and case-in-chief for its crossclaims against Carleton; Defendant Pape will present its 11 defense and case-in-chief for its crossclaims against Carleton and Momentum; then Defendant 12 Carleton will present its defense case-in-chief for its crossclaims against Momentum and Pape.

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