Lisa Vargas v. County of Los Angeles

CourtDistrict Court, C.D. California
DecidedFebruary 27, 2023
Docket2:19-cv-03279
StatusUnknown

This text of Lisa Vargas v. County of Los Angeles (Lisa Vargas v. County of Los Angeles) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lisa Vargas v. County of Los Angeles, (C.D. Cal. 2023).

Opinion

Case 2:19-cv-03279-MEMF-AS Document 320 Filed 02/27/23 Page 1 of 22 Page ID #:14308

1 O

7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9

10 LISA VARGAS, Case No.: 2:19-cv-03279-MEMF-(ASx) 11 Lisa Vargas, ORDER ON DEFENDANTS’ MOTIONS IN 12 LIMINE [ECF NOS. 253–61, 265, 270] AND v. PLAINTIFF LISA VARGAS’S MOTIONS IN 13 LIMINE [ECF NOS. 262–64, 266–69]

14 COUNTY OF LOS ANGELES, et al.,

15 Defendants.

19 Before the Court are twelve (12) motions in limine filed by Defendants County of Los 20 Angeles, Nikolis Perez, and Jonathan Rojas (ECF Nos. 253–61, 265, 270) and seven (7) motions in 21 limine filed by Plaintiff Lisa Vargas (ECF Nos. 262–64, 266–69). For the reasons stated herein, the 22 Court GRANTS the motions in part. 23 24 25 26 / / / 27 / / / 28

1 Case 2:19-cv-03279-MEMF-AS Document 320 Filed 02/27/23 Page 2 of 22 Page ID #:14309

I. Factual Background 1 This case concerns a deputy-involved shooting, in which Anthony Vargas (“Anthony 2 Vargas”), Plaintiff Lisa Vargas’s son, was killed by Defendants Nikolis Perez and Jonathan Rojas 3 (“Deputy Defendants”). ECF No. 159 (“MSJ Order”) at 2. On August 28, 2018, the Deputy 4 Defendants responded to a 911 call reporting an armed robbery that had just occurred. Id. When the 5 Deputy Defendants arrived on the scene, a struggle between Anthony Vargas and the Deputy 6 Defendants ensued and the Deputy Defendants subsequently shot Anthony Vargas sixteen times. Id. 7 at 2–3. 8 II. Procedural History 9 On March 25, 2019, Plaintiff Lisa Vargas (“Lisa Vargas”) filed a complaint against 10 Defendants County of Los Angeles, Nikolis Perez, and Jonathan Rojas (collectively, the 11 “Defendants”) in Los Angeles Superior Court. On April 24, 2019, Defendants removed this case to 12 the Central District of California. ECF No. 1. On August 19, 2019, Lisa Vargas filed a First 13 Amended Complaint alleging six causes of action: (1) battery; (2) negligence; (3) violation of the 14 Bane Act, Cal. Civ. Code § 52.1; (4) unreasonable search and seizure, 42 U.S.C. § 1983; (5) 15 violation of substantive due process, 42 U.S.C. § 1983; (6) municipal liability for unconstitutional 16 custom, practice, or policy, 42 U.S.C. § 1983. ECF No. 28 (“First Amended Complaint”). 17 On October 12, 2022, Defendants filed twelve (12) motions in limine (ECF Nos. 253–61, 18 265, 270) and Lisa Vargas filed seven (7) m otions in limine (ECF Nos. 262–64, 266–69). The 19 motions were fully briefed on October 26, 2022. The Court held oral argument on the motions at the 20 Final Pretrial Conference (“FPTC”) on November 16, 2022. In advance of the FPTC, the Court 21 provided the parties with a tentative so they would be prepared to address any issues at the FPTC. 22 This Order is largely consistent with the tentative. At the FPTC, the parties submitted to all of the 23 Court’s tentative findings with the exception of Defendants’ Motion in limine No. 1 (ECF No. 253). 24 After considering the parties’ oral arguments, the Court ordered the parties to submit supplemental 25 briefing on this single motion, which they did. ECF No. 308, 310, 315. 26 / / / 27 / / / 28

2 Case 2:19-cv-03279-MEMF-AS Document 320 Filed 02/27/23 Page 3 of 22 Page ID #:14310

1 III. Applicable Law

2 A. Motions in limine

3 A motion in limine is “a procedural mechanism to limit in advance testimony or evidence in a

4 particular area.” United States v. Heller, 551 F.3d 1108, 1111 (9th Cir. 2009). A party files a motion

5 in limine to exclude anticipated prejudicial evidence before the evidence is introduced at trial. See

6 Luce v. United States, 469 U.S. 38, 40 n.2 (1984). A court has the power to grant such motions

7 pursuant to its “inherent authority to manage trials,” even though such rulings are not explicitly

8 authorized by the Federal Rules of Evidence. Id. at 41 n.4 (citation omitted). Regardless of a court’s

9 initial decision on a motion in limine, it may revisit the issue at trial. Id. at 41–42 (“[E]ven if nothing

10 unexpected happens at trial, the district judge is free, in the exercise of sound judicial discretion, to

11 alter a previous in limine ruling.”).

12 B. Federal Rule of Civil Procedure 26

13 Federal Rule of Civil Procedure 26(a)(1) provides that a:

14 party must, without awaiting a discovery request, provide to the other parties: (i) the name and, if known, the address and telephone number of each individual 15 likely to have discoverable information ... that the disclosing party may use to support its claims or defenses, unless the use would be solely for impeachment. 16 . . . 17 (iii) a computation of each category of damages claimed by the disclosing party— 18 who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary mate rial, unless privileged or protected from 19 disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered . . . . 20 Rule 26(e)(i) imposes a duty on parties to supplement their Rule 26(a) disclosures if 21 the party learns that its disclosures are incomplete or incorrect. Rule 37(c)(1) gives teeth to 22 these requirements by forbidding the use at trial of any information required to be disclosed 23 by Rule 26(a) that is not properly disclosed. Yeti by Molly, Ltd. v. Deckers Outdoor Corp., 24 259 F.3d 1101, 1106 (9th Cir. 2001). However, the Court provides two exceptions for when 25 the information may still be introduced: if the parties’ failure to disclose the required 26 information is substantially justified or harmless. Id. (citing Fed. R. Civ. P. 37(c)(1)). 27 28

3 Case 2:19-cv-03279-MEMF-AS Document 320 Filed 02/27/23 Page 4 of 22 Page ID #:14311

1 “Implicit in Rule 37(c)(1) is that the burden is on the party facing sanctions to prove

2 harmlessness.” Yeti, 259 F.3d at 1107.

3 Federal Rule of Civil Procedure 26(a)(1)(A) requires parties to provide initial

4 disclosures to the opposing parties without awaiting a discovery request. The initial

5 disclosures must include a computation of each category of damages claimed by the

6 disclosing party. Fed. R. Civ. P. 26(a)(1)(A)(iii).

7 While Rule 26 generally requires a party to provide a computation of such damages,

8 emotional damages, because of their vague and unspecific nature, are oftentimes not readily

9 amenable to computation. See Williams v. Trader Publishing Co., 218 F.3d 481, 486 n. 3 (5th

10 Cir.2000) (“Since compensatory damages for emotional distress are necessarily vague and

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