Martin v. City of San Jose

District Court, N.D. California·Decided May 6, 2021·No. 3:19-cv-01227·Unknown

Opinion

1 2 3 6 7 ANDY MARTIN, Case No. 19-cv-01227-EMC

8 Plaintiff, ORDER RE AMENDED EXHIBIT 9 v. LISTS

10 CITY OF SAN JOSE, et al., Docket Nos. 87, 89 11 Defendants.

12 13 14 Below are the Court’s rulings on the parties’ exhibits. 15 17 18 Dated: May 6, 2021 19 20 ______________________________________ EDWARD M. CHEN 21 United States District Judge

22 23 24 25 26 27 1 3 1 Photographs of P’s injuries Rule 403 objection overruled. 4 2 Excerpt from Duty Manual (Use of Relevance objection overruled. Ruling on 5 the Police Vehicle) remaining objections (hearsay and foundation) 6 deferred. Regarding hearsay, the Duty Manual 7 may be admissible as long as the necessary 8 predicate is laid. See, e.g., Fed. R. Evid. 9 801(d)(2) (statement of party-opponent); Fed. 10 R. Evid. 803(6) (business record); 803(8) 11 (public record). The Duty Manual is also at 12 issue in Exs. 3-4. 13 3 Excerpt from Duty Manual Relevance objection overruled. Ruling on 14 (Traffic Accidents) remaining objections (hearsay and foundation) 15 deferred. See Ex. 2. 16 4 Excerpt from Duty Manual (use of Relevance objection deferred. As a facial 17 force) matter, the only policies that seem to be 18 relevant are those on the use of the police 19 vehicle (which is duplicative of Ex. 2 above), 20 the reporting of force, and the review of the use 21 of force. Ruling on remaining objections 22 (hearsay and foundation) also deferred. See Ex. 23 2. 24 5 Excerpt from Cal. Comm’n on Relevance objection overruled. Ruling on 25 Peace Officer Standards and remaining objections (hearsay and foundation) 26 Training (POST), Basic Workbook deferred. See Ex. 2. 27 Series, Student Materials, 2 Operations (e.g., defensive 3 driving, factors affecting vehicle 4 operations, emergency driving, 5 operating emergency response 6 vehicles, vehicle pursuits, vehicle 7 dynamics, vehicle control 8 techniques) 9 6 Scene photographs Rule 403 objection overruled. 10 7 Video of operation of police Relevance and hearsay objections overruled. 11 vehicle (not on the day of the Ruling on the remaining objection (foundation) 12 incident) deferred. Statements on the video are not 13 describing or explaining an event or condition, 14 and are not made to prove the truth of their 15 content. Instead, the statements on the video 16 are largely directions given to the person 17 operating the vehicle to provide context. 18 8 Video from Officer Gutierrez’s Ruling deferred. The Court cannot assess the 19 body-worn camera relevance, Rule 403, hearsay, and foundation 20 objections because Plaintiff has not designated 21 what portions of the 28-minute video he seeks 22 to admit into evidence. The video itself is not 23 hearsay but statements made on the video may 24 or may not be hearsay – e.g., certain statements 25 on the video may be subject to exceptions such 26 as present sense impression. See United States 27 v. Alexander, 331 F.3d 116, 123 (D.C. Cir. 2 held that, if video includes an officer (not 3 Officer Ribeiro) falsely telling the cousin that 4 Mr. Martin admitted he had a weapon or that a 5 weapon had been found, that evidence is not 6 permitted unless the door is opened (e.g., for 7 impeachment). See PTC Order at 20 8 (addressing D’s MIL No. 6). 9 9 Excerpts from report authored by Plaintiff has stated (in response to Defendants’ 10 IA Investigator, Officer Peroutka MIL No. 5) that he does not intend to offer the 11 conclusions of the report into evidence. 12 Relevance objection overruled. Remaining 13 objections (Rule 403, hearsay, and foundation) 14 deferred. Regarding hearsay, the report itself 15 may qualify as a public record under Rule 16 803(8); alternatively, the report may be a 17 statement of party-opponent (as to the City at 18 least). However, the report may or may not 19 contain hearsay. To the extent the report 20 contains statements from Officer Ribeiro, those 21 would be statements of a party-opponent under 22 Rule 801(d)(2) as to Officer Ribeiro and may be 23 statements of a party-opponent as to the City. 24 See PTC Order at 18-20 (addressing D’s MIL 25 No. 5). See, e.g., Freitag v. Ayers, 468 F.3d 26 523, 541 & n.5 (9th Cir. 2006) (in hostile work 27 environment case, holding that district court did 2 enumerated the agency's findings that, among 3 other things, the administrative staff at Pelican 4 Bay had not responded appropriately to the 5 concerns expressed by female officers about 6 exhibitionist masturbation, and the institution 7 had not taken adequate steps to correct the 8 problem”); Jessup v. Miami-Dade Cty., 697 F. 9 Supp. 2d 1312, 1322 (S.D. Fla. 2010) (stating 10 that, “while ‘factual findings’ in internal affairs 11 reports are generally admissible under an 12 exception to the hearsay rule, Fed. R. Evid. 13 803(8), summaries of interviews that are 14 contained in those reports are also double 15 hearsay that cannot be admitted at trial or 16 considered on summary judgment”); Murphy v. 17 Metro. Transp. Auth., 548 F. Supp. 2d 29, 43 18 (S.D.N.Y. 2008) (stating that “internal police 19 investigations – when they are relevant – are 20 presumed admissible in a civil case as public 21 record exceptions to the hearsay rule”). 22 10 Computer-aided dispatch Relevance objection overruled. The phone 23 number of the third party should be redacted. 24 11 Video from Officer Serrano’s Ruling deferred. The Court cannot assess the 25 body-worn camera relevance, Rule 403, and hearsay objections 26 because Plaintiff has not designated what 27 portions of the 8-minute video he seeks to 2 hearsay but statements made on the video may 3 or may not be hearsay. See Ex. 8. 4 12 Santa Clara Valley medical Ruling deferred. The Court cannot assess the 5 records relevance, Rule 403, and hearsay objections 6 because Plaintiff has not designated what 7 portions of the 400+ pages of records he seeks 8 to admit into evidence. Regarding hearsay, the 9 medical records may be admissible as business 10 records; however, the records may or may not 11 contain hearsay. Statements of Mr. Martin are 12 not admissible under Rule 801(d)(2) because 13 they are his own statements and not those of a 14 party-opponent. Absent narrowing of what Mr. 15 Martin seeks to admit, Court cannot determine 16 which, if any, exceptions might apply. 17 13 Santa Clara Regional medical Ruling deferred. The Court cannot assess the 18 records relevance, Rule 403, and hearsay objections 19 because Plaintiff has not designated what 20 portions of the almost 500 pages of records he 21 seeks to admit into evidence. Regarding 22 hearsay, the medical records may be admissible 23 as business records; however, the records may 24 or may not contain hearsay. Statements of Mr. 25 Martin are not admissible under Rule 801(d)(2) 26 because they are his own statements and not 27 those of a party-opponent. See Ex. 12. 2 organs, including the pelvic area objection if the exhibit were to be used as a 3 (exhibit used in Dr. Yun demonstrative only; Plaintiff has confirmed that 4 deposition) the exhibit is to be used as a demonstrative 5 only. 6 15 Expert report of Dr. Smith Hearsay objection sustained. However, 7 (biomechanical engineer opining Plaintiff may use the report to refresh 8 on injury causation) recollection. 9 16 Exhibits from Dr. Smith’s expert Ruling on relevance, Rule 403, and hearsay 10 report (syncing of video from objections deferred. Regarding hearsay, the 11 Officer Ribeiro and Officer videos are not hearsay but statements on the 12 Purnell’s body-worn cameras) videos may or may not be hearsay and may be 13 subject to hearsay exceptions.

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