J.R. Simplot Company v. Kadyn Del Toro

District Court, D. Idaho·Decided August 12, 2026·No. 1:22-cv-00408·Unknown

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

J.R. SIMPLOT COMPANY, Case No. 1:22-cv-00408-DKG Plaintiff,

MEMORANDUM DECISION AND v. ORDER KADYN DEL TORO, an individual, Defendant.

INTRODUCTION Before the Court are Motions in Limine filed by each party. (Dkt. 111, 113). The motions are fully briefed. (Dkt. 115, 119). On August 11, 2026, a pre-trial conference was held where the parties presented oral argument on the motions in limine. (Dkt. 106, 110). This order formalizes the Court’s oral rulings and statements made during the hearing and is intended to give the parties direction on the evidentiary issues that have been raised by the parties. These rulings are preliminary and are subject to revision upon consideration of a particular evidentiary issue presented within the context of the trial. BACKGROUND1 This action arises out of allegations that Defendant Kadyn Del Toro (Del Toro), a

former employee of Plaintiff J.R. Simplot Company (Simplot), took confidential and trade secret materials belonging to Simplot when he left to work for another company, Wilbur-Ellis Company, LLC (Wilbur-Ellis). The materials allegedly taken by Del Toro were digital files allegedly copied to, stored on, used, and/or accessed through various computers and digital storage devices. The parties have engaged in extensive discovery, including the use of experts to conduct forensic examinations of the computers and

digital devices. The parties strongly dispute what the evidence shows and the facts underlying the claims. On April 25, 2025, the Court issued decisions on the parties’ cross motions for summary judgment and motions to exclude evidence from the expert witnesses. (Dkt. 103, 104). Those decisions provided substantial guidance concerning evidence and

testimony, and narrowed the claims proceeding to trial. Trial is set to begin September 8, 2026. (Dkt. 110). On July 17, 2026, the parties filed motions in limine, which the Court addressed during the hearing and as stated herein. (Dkt. 111, 113). LEGAL STANDARDS “A motion in limine is a procedural mechanism to limit in advance testimony or

evidence in a particular area.” Hana Fin., Inc. v. Hana Bank, 735 F.3d 1158, 1162 n. 4 (9th Cir. 2013) (quoting United States v. Heller, 551 F.3d 1108, 1111 (9th Cir. 2009)).

1 Because the factual and procedural background of this case have been set forth in prior orders and are well known to the Court and counsel, they are not restated in their entirety here. There is no express authority for motions in limine in either the Federal Rules of Civil Procedure or the Federal Rules of Evidence. Nevertheless, these motions are well

recognized in practice and by case law. See, e.g., Ohler v. United States, 529 U.S. 753, 758 (2000). The key function of a motion in limine is to “exclude prejudicial evidence before the evidence is actually offered.” Luce v. United States, 469 U.S. 38, 40 (1984). Generally, motions in limine excluding broad categories of evidence are disfavored—as such issues are more fairly dealt with during trial as the admissibility of evidence arises. Sperberg v. Goodyear Tire & Rubber, Co., 519 F.2d 708, 712 (6th Cir.

1975). Additionally, it is sometimes necessary to defer ruling until trial when a better estimate of the impact of the evidence on the jury can be made by the trial judge. Crawford v. City of Bakersfield, No. 1:14-cv-01735-SAB, 2016 WL 5870209, at *2 (E.D. Cal. Oct. 6, 2016). Denial of a motion in limine does not mean that all evidence contemplated by the

motion will be admitted at trial. Instead, denial of such a motion simply means the Court is unable to determine whether the evidence should be excluded outside of the trial context. At trial, the parties may object to the offering of evidence even though such evidence was the subject of the Court’s denial of a motion in limine. Where a motion in limine is granted, however, the parties are precluded from arguing, discussing, or offering

the particular evidence that the Court has ordered be excluded unless the Court rules otherwise during the course of the trial. DISCUSSION 1. Plaintiff’s Motion in Limine

Plaintiff submits three motions in limine seeking to exclude evidence of the following: 1) other lawsuits or disputes by Wilbur-Ellis; 2) a party’s relative financial size outside the context of expert opinion; and 3) that any delay in proceeding to trial was a tactic used to punish the other party. (Dkt. 113). Defendant opposes the second motion and does not oppose the other two motions, with some explanation. (Dkt. 115). The Court finds as follows.

A. Other Lawsuits and Disputes by Wilbur-Ellis Evidence and argument about other lawsuits and disputes filed by Wilbur-Ellis against Simplot or its employees is irrelevant and unduly prejudicial. Fed. R. Evid. 401, 402, 403. The motions in limine filed by both parties relevant to this subject matter are therefore granted. (Dkt. 111, 113).

B. A Party’s Relative Financial Size Excluding Expert Opinions Generally speaking, evidence, testimony, and argument about a party’s financial size relative to another party is irrelevant and unduly prejudicial to the extent it seeks to improperly appeal to the sympathy of jurors through references to financial disparity. See e.g., Old Chief v. United States, 519 U.S. 172, 180 (1997) (“[As] the Committee Notes to

Rule 403 explain, [u]nfair prejudice within its context means an undue tendency to suggest decision on an improper basis, commonly, though not necessarily, an emotional one,” quoting Fed. R. Evid. 403, Advisory Committee’s Notes (internal quotation marks omitted)). Thus, evidence of the relative size or wealth of a party cannot be used to sway the jury’s verdict based on bias or prejudice. Draper v. Airco, Inc., 580 F.2d 91, 95 (3rd Cir. 1978) (“[J]ustice is not dependent upon the wealth or poverty of the parties and a

jury should not be urged to predicate its verdict on a prejudice against bigness or wealth.”); Fed. R. Evid. 403. To that end, where the wealth and size of a party are not at issue, counsel should generally refrain from referring to the same or eliciting testimony that improperly prejudices the jury. However, where such matters are at issue, evidence about the wealth and size of a party may be admissible where the evidence is relevant to and probative of the merits of the claim. Fed. R. Evid. 401, 402; see e.g., White v. Ford

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J.R. Simplot Company v. Kadyn Del Toro, (D. Idaho 2026).

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Related

Luce v. United States
469 U.S. 38 (Supreme Court, 1984)
Old Chief v. United States
519 U.S. 172 (Supreme Court, 1997)
Ohler v. United States
529 U.S. 753 (Supreme Court, 2000)
Lawrence R. Sperberg v. Goodyear Tire & Rubber Co.
519 F.2d 708 (Sixth Circuit, 1975)
White v. Ford Motor Co.
500 F.3d 963 (Ninth Circuit, 2007)
United States v. Heller
551 F.3d 1108 (Ninth Circuit, 2009)
Hana Financial, Inc. v. Hana Bank
735 F.3d 1158 (Ninth Circuit, 2013)
Danny Snapp v. Bnsf Railway Co.
889 F.3d 1088 (Ninth Circuit, 2018)
Draper v. Airco, Inc.
580 F.2d 91 (Third Circuit, 1978)