Maldonado v. Krawczyk

CourtDistrict Court, W.D. New York
DecidedFebruary 3, 2025
Docket6:18-cv-06021
StatusUnknown

This text of Maldonado v. Krawczyk (Maldonado v. Krawczyk) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maldonado v. Krawczyk, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

EDWIN MALDONADO, DECISION AND ORDER Plaintiff, Vv. 6:18-CV-06021 CDH J. KRAWCZYK, G. MANOCCHIO, and E. KING, Defendants

BACKGROUND Plaintiff Edwin Maldonado (“Maldonado”) has asserted a claim of excessive force under 42 U.S.C. § 1983 against defendants J. Krawezyk (“Krawcyzk”), G. Manocchio (“Manocchio”), and E. King (“King”) (collectively “Defendants”). A jury trial is scheduled to commence on February 18, 2025. (Dkt. 81). The parties have filed motions in limine regarding evidentiary issues they anticipate arising at trial, as to which briefing is complete. (Dkt. 78-1; Dkt. 80-3; 85; Dkt. 86). The Court heard oral argument on January 21, 2025, at which time it advised the parties of its tentative rulings as to some of the evidentiary issues, but indicated that it would issue a written decision setting forth its final determinations. (Dkt. 88). This Decision and Order sets forth the Court’s resolution of the legal issues raised in the parties’ motions in limine. For the reasons that follow, the Court grants

1 The parties have consented to have a United States Magistrate Judge conduct all proceedings in this case, including trial, entry of final judgment, and all post-trial proceedings, pursuant to 28 U.S.C. § 636 and Federal Rule of Civil Procedure 73. (Dkt. 62).

in part and denies in part both Maldonado’s motion in limine and Defendants’ motion in limine. DISCUSSION

The parties’ motions in limine raise the following issues: (1) the admissibility of Maldonado’s prior convictions pursuant to Federal Rule of Evidence (“FRE”) 609; (2) the admissibility of Maldonado’s prison disciplinary history pursuant to FRE 608; (3) the admissibility of evidence related to Maldonado v. Gunsett et al., No. 7:21-cv- 03719, a lawsuit brought by Maldonado in the United States District Court for the Southern District of New York in 2021; and (4) the admissibility of certain of Maldonado’s proposed testimony pursuant to Heck v. Humphrey, 512 U.S. 477 (1994)

and Edwards v. Balisok, 520 U.S. 641 (1997). The Court considers each of these issues below. I. Admissibility of Prior Convictions “Federal Rule of Evidence 609 controls the impeachment of a witness by evidence of a criminal conviction.” United States v. White, 312 F. Supp. 3d 355, 358 (E.D.N.Y. 2018). FRE 609(a)(1)(A) provides that “for a crime that, in the convicting

jurisdiction, was punishable by death or by imprisonment for more than one year, the evidence. . . must be admitted, subject to Rule 403, in a civil case[.]” Fed. R. Evid. 609(a)(1)(A). FRE 403, in turn, instructs that the Court “may exclude relevant evidence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.” Fed. R. Evid. 403. FRE 609(b) applies “if more than 10 years have passed since the witness’s conviction or release from confinement for it, whichever is later[.]” Fed. R. Evid. 609(b). Where subsection (b) applies, evidence of the prior conviction is admissible

“only if . . . its probative value, supported by specific facts and circumstances, substantially outweighs its prejudicial effect[.]” Fed. R. Evid. 609(b)(1). Maldonado has three prior felony convictions. He was convicted of grand larceny on October 10, 2002, and sentenced to a maximum term of imprisonment of four years. (Dkt. 80-5 at 2). He was convicted of robbery in the third degree on September 18, 2003, and sentenced to a maximum term of imprisonment of seven years. (Id.). Finally, he was convicted of robbery in the first degree on September 18,

2003, and sentenced to a maximum term of imprisonment of 25 years. (Id.). Maldonado was released from prison on June 13, 2024. (Dkt. 80-4 at ¶ 4). Defendants seek to impeach Maldonado with each of these prior convictions. (Dkt. 80-3 at 5-7). The factual circumstances of Maldonado’s prior convictions are described in Maldonado v. Burge, 697 F. Supp. 2d 516 (S.D.N.Y. 2010), a habeas corpus action that Maldonado brought in the Southern District of New York. In short, on two

separate occasions, Maldonado approached a stopped taxi, reached into the driver’s side window, and took money from the driver’s pocket. Id. at 519-20. On the second occasion, Maldonado climbed into the taxi, placed a pistol to the passenger’s head, and took her wallet and a chain from around her neck. Id. at 520. Initially, the Court finds that Maldonado’s convictions for grand larceny and third-degree robbery should be analyzed under FRE 609(b). While the case law on this issue is not extensive, courts that have considered the matter have concluded that a contemporaneous conviction with an extensive sentence cannot be used to “piggyback” a less-serious conviction “into the 10–year limitations period set out in

Rule 609(b).” Somerville v. Saunders, No. 9:11-CV-556 MAD/DEP, 2014 WL 272415, at *6 (N.D.N.Y. Jan. 24, 2014) (quoting United States v. Pettiford, 238 F.R.D. 33, 40 (D.D.C. 2006)). Instead, “[t]he relevant date, for purposes of calculating the applicability of Fed. R. Evid. 609(b), shall be determined based on the date on which [the older] sentence for the [ ] Felony Conviction concluded, not the date on which [the witness] was released from prison in connection with [a] concurrent sentence.” United States v. Clanton, No. 23-CR-328, 2024 WL 1072050, *15 (E.D.N.Y. Mar. 12,

2024). At oral argument, defense counsel conceded that this was an appropriate approach under FRE 609. Here, had Maldonado not been serving a 25-year sentence on his first-degree robbery conviction, he would have been released on his grand larceny conviction by no later than 2006, and on his third-degree robbery conviction by no later than 2010. Accordingly, the Court finds these convictions remote for purposes of FRE 609(b).

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Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Edwards v. Balisok
520 U.S. 641 (Supreme Court, 1997)
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Eric Jenkins v. Lt. Haubert
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Gilbert v. Cook
512 F.3d 899 (Seventh Circuit, 2008)
Maldonado v. Burge
697 F. Supp. 2d 516 (S.D. New York, 2010)
United States v. White
312 F. Supp. 3d 355 (E.D. New York, 2018)
United States v. Estrada
430 F.3d 606 (Second Circuit, 2005)
Shapard v. Attea
710 F. App'x 15 (Second Circuit, 2017)
United States v. Pettiford
238 F.R.D. 33 (District of Columbia, 2006)

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