(PC)Stevenson v. Holland

District Court, E.D. California·Decided September 23, 2021·No. 1:16-cv-01831·Unknown

Opinion

DOUGLAS J. STEVENSON, CASE NO. 1:16-cv-01831-AWI-JLT

Plaintiffs, ORDER ON OUTSTANDING MOTIONS v. IN LIMINE

K. HOLLAND, et al., (Doc. Nos. 113, 117, 121, 124, 127 & 129) Defendants.

In this order, the Court will resolve all motions in limine and judicial notice requests that were not already resolved through its previous orders on the parties’ motions in limine and Defendants’ motion for partial summary judgment. Doc. Nos. 180 & 203.1 “A motion in limine is a procedural mechanism to limit in advance testimony or evidence in a particular area.” United States v. Heller, 551 F.3d 1108, 1111 (9th Cir. 2009). Motions in limine may be “made before or during trial, to exclude anticipated prejudicial evidence before the evidence is actually offered.” Luce v. United States, 469 U.S. 38, 40 n.2 (1984). “Although the Federal Rules of Evidence do not explicitly authorize in limine rulings, the practice has developed pursuant to the district court’s inherent authority to manage the course of trials.” Id. at 4 n.4; Jonasson v. Lutheran Child & Family Servs., 115 F.3d 436, 440 (7th Cir. 1997); see also City of Pomona v. SQM N. Am. Corp., 866 F.3d 1060, 1070 (9th Cir. 2017) (explaining motions in limine

1 The rulings here were reserved in the Court’s previous order on motions in limine. Doc. No. 180 at 54. In response to that order, the parties filed supplemental briefing and submitted evidence for in camera review, after which another hearing was held. Doc. Nos. 181–183, 187, 189 & 191. The Court’s previous order on motions in limine also “are useful tools to resolve issues which would otherwise clutter up the trial” (quoted source omitted)). In Hana Financial, Inc. v. Hana Bank, the Ninth Circuit cited with approval the following “standards applicable to motions in limine”: Judges have broad discretion when ruling on motions in limine. However, a motion in limine should not be used to resolve factual disputes or weigh evidence. To exclude evidence on a motion in limine, the evidence must be inadmissible on all potential grounds. Unless evidence meets this high standard, evidentiary rulings should be deferred until trial so that questions of foundation, relevancy and potential prejudice may be resolved in proper context. This is because although rulings on motions in limine may save time, costs, effort and preparation, a court is almost always better situated during the actual trial to assess the value and utility of evidence. 735 F.3d 1158, 1162 n.4 (9th Cir. 2013) (citing Goodman v. Las Vegas Metro. Police Dep’t, 963 F. Supp. 2d 1036, 1047 (D. Nev. 2013), rev’d in part on other grounds by 613 F. App’x 610 (9th Cir. 2015)); see also Tritchler v. County of Lake, 358 F.3d 1150, 1155 (9th Cir. 2004); Jenkins v. Chrysler Motors Corp., 316 F.3d 663, 664 (7th Cir. 2002). By resolving a motion in limine, the court may prevent the presentation of potentially prejudicial evidence to the jury, which also eliminates the need to try to neutralize a prejudicial taint after the evidence has already been presented. See Brodit v. Cambra, 350 F.3d 985, 1004–05 (9th Cir. 2003). Notwithstanding a motion in limine ruling, a court may change course at trial in the event that testimony or other evidence “bring[s] facts to the district court's attention that it did not anticipate at the time of its initial ruling.” United States v. Bensimon, 172 F.3d 1121, 1127 (9th Cir. 1999) (citing Luce, 469 U.S. at 41–42). As to general admissibility standards, evidence is relevant if (a) it has any tendency to make a fact more or less probable than it would be without the evidence; and (b) the fact is of consequence in determining the action. Fed. R. Evid. 401. Irrelevant evidence is not admissible. Fed. R. Evid. 402. “Relevancy is not an inherent characteristic of any item of evidence but exists only as a relation between an item of evidence and a matter properly provable in the case.” Sprint/United Mgmt. Co. v. Mendelsohn, 552 U.S. 379, 387 (2008) (quoting Fed. R. Evid. 401 advisory committee notes). Even if relevance is established, the court may exclude 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. In general, “[e]vidence of a person’s character or character trait is not admissible to prove that on a particular occasion the person acted in accordance with the character or trait.” Fed. R. Evid. 404(a)(1). Likewise, “[e]vidence of a crime, wrong, or other act is not admissible to prove a person’s character in order to show that on a particular occasion the person acted in accordance with the character.” Fed. R. Evid. 404(b)(1). The outstanding matters that the Court will resolve in this order are Defendants’ Motions in Limine Nos. 2 and 14 and Stevenson’s Motion in Limine No. 13 and Requests for Judicial Notice Nos. 1 and 2.2 A. Defendants’ Motion No. 2 concerning Defendant Crotty’s personnel records Defendants seek an order excluding the discussion or introduction as evidence of Defendant M. Crotty’s personnel records at trial. Doc. No. 113. 1. The parties’ arguments: Defendants argue that Crotty’s records are not admissible. They first contend that the records are not relevant to Stevenson’s claims and allegations that Crotty used excessive force. They further argue that even if the records are relevant, they are not proportional to the needs of the case and would instead unfairly prejudice Crotty, confuse the issues, mislead the jury, and waste time. Finally, Defendants argue that Stevenson should not be allowed to use the records as improper character evidence. In opposition, Stevenson first agrees that the records may not be admitted to show that Crotty acted in accordance with an earlier instance of bad character. Doc. No. 145 at 3. But he contends the records and their contents are generally admissible as evidence bearing on Crotty’s 2 The Court’s resolution of Defendants’ partial summary judgment motion takes the place of its resolution of credibility and truthfulness. Stevenson asserts that the records should be admissible upon cross- examination for impeachment purposes, and also requests permission to question Crotty regarding these subjects dur

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