(PC) Bush v. Santoro

CourtDistrict Court, E.D. California
DecidedJanuary 31, 2024
Docket1:20-cv-00015
StatusUnknown

This text of (PC) Bush v. Santoro ((PC) Bush v. Santoro) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(PC) Bush v. Santoro, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 JAMES S. BUSH, Case No.: 1:20-cv-00015 JLT EPG (PC) 12 Plaintiff, ORDER ON MOTIONS IN LIMINE 13 v. (Docs. 117, 119, 121–129) 14 K. SANTORO, et al., 15 Defendants.

16 17 I. FACTUAL BACKGROUND 18 James Bush is an inmate at North Kern State Prison. He brings this action pursuant to 42 19 U.S.C. § 1983 alleging the use of excessive force against him, in violation of his Eighth 20 Amendment rights.1 (Doc. 37 at 2–6; Doc. 106 at 2.) The parties have submitted several motions 21 in limine regarding evidence expected to be presented at trial. (See Docs. 117, 119, 121–29.) 22 The Court finds the matters suitable for decision without oral argument pursuant to Local Rule 23 230(g) and General Order 618. 24 A. LEGAL STANDARDS GOVERNING MOTIONS IN LIMINE 25 “Although the Federal Rules of Evidence do not explicitly authorize in limine rulings, the 26 1 Originally, Plaintiff named Rusmelinda Hilario and R. Flowers as defendants, asserting that they were 27 deliberately indifferent to his medical needs. (See Doc. 37 at 6.) On March 6, 2023, Plaintiff filed a 28 request for a voluntarily dismissal of Flowers and Hilario with prejudice pursuant to Federal Rule of Civil 1 practice has developed pursuant to the district court’s inherent authority to manage the course of 2 trials.” Luce v. United States, 469 U.S. 38, 40 n. 2 (1984). The Ninth Circuit explained that 3 motions in limine “allow parties to resolve evidentiary disputes ahead of trial, without first having 4 to present potentially prejudicial evidence in front of a jury.” Brodit v. Cabra, 350 F.3d 985, 5 1004–05 (9th Cir. 2003) (citations omitted). 6 Courts disfavor motions in limine seeking to exclude broad categories of evidence. See 7 Sperberg v. Goodyear Tire and Rubber Co., 519 F.2d 708, 712 (6th Cir. 1975). The Court “is 8 almost always better situated during the actual trial to assess the value and utility of evidence.” 9 Wilkins v. Kmart Corp., 487 F. Supp. 2d 1216, 1218 (D. Kan. 2007). The Sixth Circuit explained, 10 “[A] better practice is to deal with questions of admissibility of evidence as they arise [in trial].” 11 Sperberg, 519 F.2d at 712. Nevertheless, motions in limine are “an important tool available to the 12 trial judge to ensure the expeditious and evenhanded management of the trial proceedings.” 13 Jonasson v. Lutheran Child & Family Services, 115 F.3d 436, 440 (7th Cir. 1997). 14 “[A] motion in limine should not be used to resolve factual disputes or weigh evidence,” 15 C & E Services, Inc. v. Ashland Inc., 539 F. Supp. 2d 316, 323 (D.D.C. 2008), because that is the 16 province of the jury. See Reeves v. Sanderson Plumbing Products, 530 U.S. 133, 150 (2000). The 17 Court will bar use of the evidence in question only if the moving party establishes that the 18 evidence clearly is not admissible for any valid purpose. Jonasson, 115 F. 3d at 440. Ontge other 19 hand, the rulings on the motions in limine do not preclude either party from arguing the 20 admissibility of the evidence discussed herein, if the evidence adduced at trial demonstrates a 21 change of circumstances that would make the evidence admissible. In this event, the proponent 22 of the evidence SHALL raise the issue with the Court outside the presence of the jury. 23 II. DISCUSSION 24 A. Stipulated Motions in Limine 25 The parties stipulate to the following: 26 • Neither party will offer undisclosed expert witnesses or undisclosed expert 27 opinions via those witnesses, and neither party will seek expert opinion from lay 28 witnesses. 1 • Neither party will elicit testimony regarding the individual parties’ financial 2 condition, or that Defendants are indemnified by the California Department of 3 Corrections and Rehabilitation. 4 • Defendants will not identify, in their opening statement, any specific individual as 5 an alternative attacker who caused Plaintiff’s alleged injuries. 6 • Plaintiff will not introduce any evidence of prior complaints, appeals, or 7 grievances previously submitted by an inmate or individual against Defendants or 8 CDCR witnesses or evidence from Defendants’ personnel files regarding any staff 9 complaints or reprimands. 10 (Doc. 119 at 1–2.) The Court accepts the stipulation. 11 B. Defendants’ Motions in Limine 12 1. Motion in Limine No. 1 (Doc. 117): Exclusion of Witness Statements, 13 Incident Reports, and Photographs 14 Defendants’ first motion in limine requests the exclusion of several documents because 15 they contain inadmissible hearsay, violate the Court’s Protective Order in this case, “for which no 16 order or agreement has been obtained to be presented at trial,” or they would constitute 17 cumulative evidence under Rule 403. (See Doc. 117 at 2.) Defendants also state that they reserve 18 their rights to object to Plaintiff’s exhibits and witnesses at trial. (Id. at 5.) The Court addresses 19 each request in turn. 20 a. Hearsay Objection 21 First, Defendants move to exclude the witness statements of four non-testifying inmates, 22 collected during the internal investigation into Plaintiff’s allegations. (Doc. 117 at 3.) 23 Defendants maintain that witness statements contained within the ISU’s investigative report are 24 hearsay for which no exception applies. (Id.) Defendants report that, “Plaintiff has neither made 25 any showing as to [their] unavailability . . . nor indicated their intent to call” these witnesses. (Id.) 26 Defendants also move to exclude Plaintiff’s grievance statement and witness statement, as 27 well as twenty incident reports, interview statements, and witness statements. (Id.) They state 28 that these “are all incomplete fragments of hearsay documents” and that “none of these statements 1 fall into a hearsay exception.” (Id. at 4.) Defendants only request that these exhibits “be 2 referenced for impeachment or rehabilitation purposes.” (Id.) 3 Plaintiff indicates that he “likely will not seek to enter these documents into evidence but 4 included them on his exhibit list so they could be used at trial to refresh recollection, for 5 impeachment, or for any other identification-related purpose.” (Doc. 132 at 2 (emphasis in 6 original).) Furthermore, Plaintiff contests the applicability of the hearsay doctrine to several 7 incident reports and grievance statements and represents that he may “offer them for a non- 8 hearsay purpose” at trial, or alternatively, that they may fall into a hearsay exception. (Id. at 2–3.) 9 The Court agrees that these documents are filled with varying levels of hearsay, though it agrees 10 also that there may be reasons that there may be information contained in the documents that are 11 admissible either due to an exception to hearsay or because the information is non-hearsay. Thus, 12 the Court RESERVES ruling on Defendants’ Motion in Limine No. 1 (Doc. 117) as to hearsay. 13 Should either party seek to introduce these documents, they SHALL meet and confer in advance 14 to determine whether they can come to agreement as to the admissibility of any particular 15 document. 16 b.

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Bluebook (online)
(PC) Bush v. Santoro, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-bush-v-santoro-caed-2024.