Mike Dally v. State Auto Property & Casualty Insurance Company

CourtDistrict Court, D. South Dakota
DecidedMay 20, 2026
Docket4:23-cv-04175
StatusUnknown

This text of Mike Dally v. State Auto Property & Casualty Insurance Company (Mike Dally v. State Auto Property & Casualty Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. South Dakota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mike Dally v. State Auto Property & Casualty Insurance Company, (D.S.D. 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

MIKE DALLY, 4:23-CV-04175-RAL Plaintiff, OPINION AND ORDER ON vs. DEFENDANT’S MOTIONS IN LIMINE

_ STATE AUTO PROPERTY & CASUALTY INSURANCE COMPANY, Defendant.

On May 18, 2026, this Court held a pretrial conference and motion hearing where, among other things, it heard argument on Defendant State Auto Property & Casualty Insurance Company’s (State Auto) Motions in Limine, Docs. 34-45. Plaintiff Mike Dally opposes some of State Auto’s motions in limine. Doc. 53. The facts and allegations in this case are familiar to this Court as a result of the Opinion and Order denying Motion for Partial Summary Judgment, Doc. □ 28. This Court now formalizes its oral rulings with this Opinion and Order. I. Legal Standard Rulings on motions in limine are by their nature preliminary. United States v. Spotted Horse, 916 F.3d 686, 693 (8th Cir. 2019). Motions in limine “developed pursuant to the district court’s inherent authority to manage the course of trials,” Luce v. United States, 469 U.S. 38, 41 n.4 (1984), and are “specifically designed to streamline the presentation of evidence and avoid unnecessary mistrials,” Spotted Horse, 916 F.3d at 693. This practice helps safeguard the jury from hearing evidence so prejudicial that its mention could not be remedied through a corrective

instruction. Motion in limine, Black’s Law Dictionary (11th ed. 2019). Rulings on motions in limine occur before the nature and relevance of the evidence can be placed in full context. See Spotted Horse, 916 F.3d at 693. Therefore, a district court has broad discretion when ruling on ~ motions in limine and retains the authority to revisit and change its rulings based on how the case unfolds. Luce, 469 U.S. at 41-42. Ifthis Court grants a motion in limine to exclude certain information, that information must not be mentioned during voir dire, opening statements, questioning or answering by witnesses, or closing arguments, unless counsel outside the hearing of the jury obtains from this Court a contrary ruling. II. Analysis A. Motion to Exclude Discovery from Harrington Case State Auto moves to exclude references to and usage of discovery obtained in another matter, Harrington v. State Auto Property and Casualty Insurance Company, 23-cv-4190-KES}, under Federal Rules of Evidence 401, 402, and 403 and the parties’ stipulated Protective Order. Doc. 34. State Auto argues that Dally cannot rely on any discovery obtained in the Harrington matter because the evidence is irrelevant, undiscovered in this litigation, and subject to a Protective Order. Id. at 3-5. Dally does not oppose this motion in limine. Doc. 53 at 3. Therefore, this motion in limine is granted. B. Motion to Exclude References to “Biased” Expert State Auto moves to exclude references that State Auto’s expert, Lance LeTellier for Donan Engineering, is personally or through Donan Engineering a “regular vendor” or a “biased” expert that State Auto routinely hires. Doc. 35. State Auto contends that there is no discovery, and thus, no “substantial connection” to support the allegations that it hires “regular vendors” or

! The parties in the other matter are represented by the same counsel.

“biased” experts for favorable opinions. Id. at 6-7. Dally opposes this motion in limine. Doc. 53 at 3. He contends that State Auto’s adjuster Carey Hubbard testified in his deposition that State Auto generally uses two engineering firms and relies solely on the firms’ reports, without giving them a copy of the insurance policy, “to the exclusion of all other evidence.” Id. at 3-4. Dally argues State Auto’s use of the same engineering firm coupled with the incentive to pay as little as possible on claims “supports reasonable inferences and circumstantial evidence of bias and of State Auto’s use of its preferred vendor.” Id. at 7.: Relevant evidence means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence. Fed. R. Evid. 401. “Evidence of bias is relevant to impeach a witness.” Russell v. Anderson, 966 F.3d 711, 730 (8th Cir. 2020) (citing United States v. Abel, 469 U.S. 45, 51 (1984)). “Relevant evidence is admissible unless any of the following provides otherwise: the United States Constitution; a federal statute; these rules; or other rules prescribed by the Supreme Court. Inrélevant evidence is not admissible.” Fed. R. Evid. 402. Relevant evidence may be excluded “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. This motion in limine is denied in part. Dally has elicited testimony in depositions □□□□□ show LeTellier routinely works for insurance companies and that State Auto uses Donan Engineering as one of its authorized engineering firms. Doc. 51-2 at 18-19; Doc. 51-3 at 4. Evidence that Dally seeks to introduce regarding Donan Engineering’s bias or its engineer LeTellier’s bias is relevant to challenge the reliability of that engineering opinion. Cross- -examination of LeTellier concerning past work of Donan Engineering and himself for State Auto

and on which side (insurer or insured) they routinely work is admissible on possible bias. See Russell, 966 F3d at 730 (citing Abel, 469 U.S. at 51). C. Motion to Exclude References to Improper Data Entry State Auto moves to exclude references to State Auto’s employees’ improper data entry into the claim file. Doc. 36. State Auto argues that Dally has not produced any evidence supporting the claim that State Auto improperly entered data on his file making the claim irrelevant and unfairly prejudicial. Id. at 4-5. Dally does not oppose this motion in limine, Doc. 53 at 7, 50 the motion is granted. D. Motion to Exclude RoofHawk Report State Auto moves to exclude all evidence related to the “RoofHawk” report provided by Good Faith Public Adjusting under Federal Rules of Evidence 403, 702, and 802. Doc. 37. State Auto argues that 1) Brandon Anderson of Good Faith Public Adjusting cannot testify to the contents of the RoofHawk report because he was not disclosed as an expert, 2) the RoofHawk report lacks an adequate foundation, 3) the RoofHawk Report will only mislead and confuse the jury, and 4) the RoofHawk report is inadmissible hearsay. Id. at 5-8. Dally does not oppose this motion in limine, Doc. 53 at 7, so the motion is granted. E. Motion to Exclude References to “Pattern and Practice” of Bad Faith State Auto moves to exclude any reference to an alleged “pattern and practice of bad faith” as not relevant under Federal Rules of Evidence 401, 402, and 403. Doc. 38. State Auto contends that Dally has not gathered any evidence to support the assertion that State Auto has a “pattern and

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Related

Luce v. United States
469 U.S. 38 (Supreme Court, 1984)
United States v. Abel
469 U.S. 45 (Supreme Court, 1984)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
Timothy Duane Arcoren v. United States
929 F.2d 1235 (Eighth Circuit, 1991)
Bertelsen v. Allstate Insurance Co.
2011 S.D. 13 (South Dakota Supreme Court, 2011)
Brown v. Fred's, Inc.
494 F.3d 736 (Eighth Circuit, 2007)
Sappington v. Skyjack, Inc.
512 F.3d 440 (Eighth Circuit, 2008)
American Automobile Insurance v. Omega Flex, Inc.
783 F.3d 720 (Eighth Circuit, 2015)
United States v. Chavez Spotted Horse
916 F.3d 686 (Eighth Circuit, 2019)
David Russell v. Edward Anderson
966 F.3d 711 (Eighth Circuit, 2020)

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Bluebook (online)
Mike Dally v. State Auto Property & Casualty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mike-dally-v-state-auto-property-casualty-insurance-company-sdd-2026.