Jones v. Kenton County, Kentucky

District Court, E.D. Kentucky·Decided July 31, 2025·No. 2:23-cv-00164·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION (at Covington)

TONYA JONES, Administratrix of the ) Estate of John Daulton, ) ) Plaintiff, ) Civil Action No. 2: 23-164-DCR ) V. ) ) KENTON COUNTY, KENTUCKY ) MEMORANDUM OPINION ) AND ORDER Defendant. ) )

*** *** *** *** This matter is pending for consideration of two in limine motions filed by Defendant Kenton County and a separate motion for reconsideration of the Court’s Memorandum Opinion and Order partially denying Kenton County’s earlier motion for summary judgment. The first motion in limine [Record No. 66] will be granted, in part, and denied, in part. The second motion in limine [Record No. 74] will be granted in its entirety. Finally, the motion for reconsideration [Record No. 74] will be denied. I. Background This action was initiated by Plaintiff Tonya Jones (“Jones”), as the administratrix of the estate of John Daulton (“Daulton”), after Daulton was allegedly violently attacked by Jonathan Maskiell in a shared cell at the Kenton County Detention Center (“KCDC”).1 Daulton passed away from his injuries a week later. For the reasons outlined in the Court’s

1 A more detailed account of the alleged facts can be found in the Court’s Memorandum Opinion and Order at Record No. 69. - 1 - June 4, 2025, Memorandum Opinion and Order, Jones’ claims against individual Defendants deputy jailers Kristin Wehrer and Jared Capps were dismissed, and Jones’ claim for failure to train or supervise asserted against Kenton County was permitted to proceed to trial.2

II. The Omnibus Motion in Limine A party through a motion in limine seeks “to exclude anticipated prejudicial evidence before the evidence is actually offered.” Louzon v. Ford Motor Co., 718 F.3d 556, 561 (6th Cir. 2013) (citing Luce v. United States, 469 U.S. 38, 40 n.2 (1984)). “[M]otions in limine are not intended to resolve factual disputes,” and courts should only exclude challenged evidence when it is “clearly inadmissible.” Louzon v. Ford Motor Co., 718 F.3d 556, 561 (6th Cir. 2013) (citing Williams v. Johnson, 747 F. Supp. 2d 10, 14 (D.D.C. 2010)). Although district

courts enjoy “broad discretion in determining the relevancy of evidence and in passing upon its admissibility under Rule 401,” the “better practice is to defer evidentiary rulings until trial unless the evidence is clearly inadmissible on all potential grounds.” Middleton v. SelecTrucks of Am., LLC, 589 F. Supp. 3d 687, 691 (W.D. Ky. 2022) (citation modified). As such, a court’s ruling in limine is “no more than a preliminary, or advisory, opinion” that may be altered or amended at trial. United States v. Yannott, 42 F.3d 999, 1007 (6th Cir. 1994) (citing United

States v. Luce, 713 F.2d 1236, 1239 (6th Cir. 1983)). Additionally, Rule 26 of the Federal Rules of Civil Procedure requires parties to disclose individuals and documents “that the disclosing party may use to support its claims or defenses, unless the use would be solely for impeachment.” Fed. R. Civ. P. 26(a)(1)(A)(i)-(ii). And Rule 37 of the Federal Rules of Civil Procedure outlines sanctions for failure to comply

2 See Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978). - 2 - with Rule 26. “If a party fails to provide information or identify a witness as required by Rule 26(a) or (e), the party is not allowed to use that information or witness to supply evidence on a motion, at a hearing, or at a trial, unless the failure was substantially justified or is harmless.”

Fed. R. Civ. P. 37(c)(1). The Court entered a Scheduling Order pursuant to Rule 16 of the Federal Rules of Civil Procedure on May 24, 2024. [Record No. 19] It provides that “[s]upplementation under Rule 26(e) is due within thirty (30) days of the discovery of new information, but by no later than thirty (30) days prior to the close of discovery.” [Id., ¶ 3] It also requires that “[n]o later than December 31, 2024, the plaintiff must disclose the identity of expert witnesses who may be used at trial and written reports by the expert witnesses as required by Rule 26(a)(2).” [Id., ¶

2] Kenton County first moves to exclude certain witnesses and exhibits proffered by Jones on the basis that their untimely disclosure violates Rule 37(c) and the Scheduling Order. Proposed Witnesses 3-11: Kenton County challenges the admission of Jones’ proposed witnesses 3-11 on the basis that they were revealed months after the deadline outlined in the Scheduling Order. Jones disclosed Covington police officers Mathews and Igo to Kenton County as potential witnesses

on January 18, 2025. But Jones was aware that she could call them as witnesses to support her claims as early as August 6, 2024. [See Record No. 54-8, p. 2 (Kenton County Detention Center Intake Assessments for Bradley Grote and Charles Kuhl, which include Mathews and Igo as arresting officers).] Further, it appears counsel for Jones worked with an attorney in a case in which Kenton County was not a party, eliciting further information for use here. [See

- 3 - Record No. 52-12 (November 7, 2024, Deposition of officer Samuel Mathews in Kallmeyer v. Mathews, Civil Action No. 2: 24-051-DCR).] The Court may allow these witnesses to testify if Jones’ “failure [to disclose them] was

substantially justified or is harmless.” Fed. R. Civ. P. 37(c)(1). However, Jones’ late disclosure is neither substantially justified, nor harmless in this case. Regarding substantial justification, Jones points to objections to her requests for trial witnesses made by Kenton County that rely on the deadlines outlined in ¶ 10(a) of the Scheduling Order. The Scheduling Order required the parties to submit a witness list for trial by May 16, 2025. [Id., ¶ 10] Jones appears to conflate trial witnesses with individuals “likely to have discoverable information” she was required to disclose under Rule 26(a). She further asserts that she “has

followed suit by providing comprehensive disclosure of witnesses and exhibits as they became known to counsel.” [Record No. 71, p. 2] Essentially, she contends that because Kenton County refused to reveal its trial witnesses before the May 16, 2025, deadline (which was a proper objection), her late Rule 26(a) disclosures are acceptable because she was simply “following suit.” But federal court is not a playground where a “he started it” argument prevails.

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Jones v. Kenton County, Kentucky, (E.D. Ky. 2025).

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