LaVigne v. Mohegan Tribe of Indians

5 Am. Tribal Law 263, 1 M.T.C.R. 17
CourtMohegan Trial Court
DecidedSeptember 7, 2004
DocketNo. CV-04-114
StatusPublished

This text of 5 Am. Tribal Law 263 (LaVigne v. Mohegan Tribe of Indians) is published on Counsel Stack Legal Research, covering Mohegan Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LaVigne v. Mohegan Tribe of Indians, 5 Am. Tribal Law 263, 1 M.T.C.R. 17 (Mo. 2004).

Opinion

MEMORANDUM AND ORDER ON MOTION IN LIMINE

JANE W. FREEMAN, Associate Judge.

The Plaintiff has brought this action seeking reinstatement of his employment with the Mohegan Tribe and other relief. He alleges that the termination of his employment was in violation of the Mohegan Tribal Discriminatory Employment Practices Ordinance, M.T.0.2002-04, and provisions of the Mohegan Tribe’s Policies and Procedures Manual; that the procedures used to terminate his employment denied him due process; and that he has been slandered by being terminated for sexual harassment.

The Plaintiff has filed a Motion In Li-mine in which he seeks an order from this Court determining whether the Plaintiffs counsel may speak with: (1) non-managerial employees of the Defendant; (2) tribal members who are non-managerial employees of the Defendant; (3) tribal members who are not employed in any capacity by the Defendant. The Plaintiff has not provided the names of the persons with whom he wishes to speak, nor their positions if they are currently employed by the Mohegan Tribe. The Defendant has filed an Objection to Motion In Limine and argues that the motion should be denied because: (1) the Mohegan Tribal Court Rules of Practice and Procedure do not provide for a motion in limine; (2) a motion in limine is inappropriate for the relief sought by the Plaintiff; (3) the ex parte communications the Plaintiff seeks are barred by the Connecticut Rules of Professional Conduct.

I. THE LACK OF A COURT RULE ON MOTIONS IN LIMINE DOES NOT PRECLUDE COURT ACTION ON SUCH MOTIONS

The Defendant contends that this Court must deny the Motion In Limine because the Mohegan Tribal Court Rules of Practice and Procedure (“the Rules”) do not provide for such motion. While the Rules do not provide for motions in limine, other courts have considered the merits of a motion in limine even in the absence of a rule. Mulrooney v, Wambolt, 215 Conn. 211, 212, 575 A.2d 996 (1990) (Connecticut Supreme Court considered the merits of a ruling on a motion in limine prior to the 1996 adoption of Connecticut Practice Book § 15-3, adding motions in limine to the Connecticut civil rules). One authority has noted that under Connecticut’s rules [265]*265“[t]here is no requirement that a particular motion be expressly authorized in the Practice Book. Any motion which serves a legitimate purpose, is timely filed and is in proper format should not be rejected on the ground that there is no rule on the subject.” W. Horton & K. Knox, 1 Connecticut Practice Series: Practice Book Annotated, (2004 Ed.) § 11-1, author’s comments, p. 496.

Similarly, there is no requirement that a particular motion be expressly authorized by the Rules in order for it to be considered by this Court. This Court, like other courts, has the inherent power to control proceedings before it so long as such proceedings do not conflict with a rule of court or a statute (tribal ordinance). “The power of a court to manage its own affairs so as to achieve an orderly and expeditious disposition of cases exists independently of the power recognized by rule or statute.” Talit v. Northwest Airlines, 58 Conn.App. 102, 107, 752 A.2d 1131 (2000). Therefore, the absence of any provisions regarding motions in limine in the Rules does not preclude this Court from acting on such a motion filed in this Court. As hereafter set forth, the Court will not be treating this motion as a motion in limine; however, for future guidance of the parties herein, the Court nevertheless rejects the Defendant’s contention that this motion in limine must be denied because it is not provided for in the Rules.

II. WHILE A MOTION IN LIMINE MAY NOT BE THE PROPER MOTION TO SECURE THE RELIEF SOUGHT BY THE PLAINTIFF, THE COURT WILL TREAT THE PLAINTIFF’S MOTION AS A MOTION FOR AN ORDER CONCERNING ACCESS TO WITNESSES

Motions in limine have long been employed in civil and criminal proceedings to obtain (1) rulings in advance of trial on the admissibility of evidence and (2) orders prohibiting opposing counsel, their clients and their witnesses from displaying, offering or making reference to specified prejudicial evidence in a jury’s presence. Tail’s Handbook of Connecticut Evidence, § 1.34.1, 3rd Ed., 2001. The Plaintiff is not seeking either type of order or ruling but instead is seeking a court order determining whether he may interview certain employees of the Defendant and certain tribal members (none of which are identified by name). The Mohegan Tribal Court has not yet adopted Rules of Professional Conduct for attorneys. Thus the Plaintiffs counsel essentially seeks prior Court authorization for such interviews to assure that he does not engage in conduct which this Court might consider a violation of ethical precepts prohibiting a lawyer from contacting a “party” represented by counsel, concerning the matter in representation. The Plaintiff and Defendant have both referred to Rule 4.2 of the Connecticut Rules of Professional Conduct. That rule is not specifically applicable to professional conduct of attorneys in this Court. However, until this Court adopts its own rales of Professional Conduct, there is nothing which prevents it from looking to the rules in other jurisdictions, and the cases arising under such rules, for guidance.

The purpose of court rales which prohibit communications between a lawyer for one party concerning the matter in representation, with a party he knows to be represented by a lawyer in the matter without that lawyer’s consent, is to “preserve the integrity of the lawyer-client relationship by protecting the represented party from the superior knowledge and skill of the opposing lawyer.” Pinsky v. Statewide Grievance Committee, 216 Conn. 228, 236, 578 A.2d 1075 (1990).

[266]*266The Plaintiff in the case of Morrison v. Brandeis University, 125 F.R.D. 14 (D.Mass.1989), like the Plaintiff in this case, requested court authorization to interview certain non-party employees of the Defendant without prior notice to or the consent of the Defendant’s counsel. The Defendant objected to the proposed interviews of high level faculty employees, arguing that such employees were the equivalent of “managerial employees”. The Defendant claimed that the state bar association had broadly interpreted the term “party” in the ABA Code of Profess. Resp., DR 7—104(A)(1), prohibiting communications with a represented “party”; the state bar’s interpretation, when a “party” was a corporation, required that the term “party” be construed to encompass any employee or agent of a corporate party whose statements would be admissible at trial. The Court noted that many jurisdictions had adopted this “control-group test”, drawing a distinction between members of the “control-group” on one the hand and mere employees on the other, holding that that the former are “parties” as that term is used in DR 7-104(A)(1) and the latter are not. Id. at 16.

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Related

Mulrooney v. Wambolt
575 A.2d 996 (Supreme Court of Connecticut, 1990)
Pinsky v. Statewide Grievance Committee
578 A.2d 1075 (Supreme Court of Connecticut, 1990)
Talit v. Northwest Airlines, Inc.
752 A.2d 1131 (Connecticut Appellate Court, 2000)
Morrison v. Brandeis University
125 F.R.D. 14 (D. Massachusetts, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
5 Am. Tribal Law 263, 1 M.T.C.R. 17, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lavigne-v-mohegan-tribe-of-indians-moheganct-2004.