Phillips v. DOCCS

CourtDistrict Court, N.D. New York
DecidedSeptember 7, 2023
Docket9:21-cv-00970
StatusUnknown

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

Bluebook
Phillips v. DOCCS, (N.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK ____________________________________________ CLIFTON A. PHILLIPS, JR., Plaintiff, vs. 9:21-CV-00970 DIANE HOLFORD, (MAD/CFH) Defendant. ____________________________________________ APPEARANCES: OF COUNSEL: GERBER CIANO KELLY BRADY LLP BRIAN R. BIGGIE, ESQ. 599 Delaware Avenue ROBERT P. HAMILTON, JR., ESQ. Suite 100 Buffalo, New York 14202-3702 Attorneys for Plaintiff NYS OFFICE OF THE ATTORNEY MICHAEL G. MCCARTIN, ESQ. GENERAL - ALBANY MARK J. DOLAN, ESQ. The Capitol Albany, New York 12224 Attorneys for Defendant Mae A. D'Agostino, U.S. District Judge: ORDER Plaintiff commenced this action on August 30, 2021, alleging violations of his Eighth and Fourteenth Amendment rights under the United States Constitution relative to his incarceration within the New York State Department of Corrections and Community Supervision ("DOCCS"). See Dkt. No. 1. Plaintiff later amended the complaint to include the sole remaining defendant, DOCCS Sentencing Review Coordinator Diane Holford ("Defendant" or "Defendant Holford"). See Dkt. No. 4. Trial is firmly scheduled to begin on Monday, September 11, 2023, in Albany, New York. See Dkt. No. 29. Currently pending before the Court is Defendant's motion in limine. See Dkt. No. 32. For the reasons set forth below, Defendant's motion is granted, in part, and denied, in part.1 A motion in limine enables the court to make an advance ruling on the admissibility of certain anticipated trial evidence. See Luce v. United States, 469 U.S. 38, 40 n. 2 (1984); see also Palmieri v. Defaria, 88 F.3d 136, 141 (2d Cir. 1996). Generally, "[a]ll relevant evidence is admissible" unless otherwise provided by an Act of Congress or the Federal Rules of Evidence. Fed. R. Evid. 402. For instance, Rule 403 of the Federal Rules of Evidence grants the trial court

"broad discretion to exclude even relevant evidence if its probative value is substantially outweighed by the danger of confusion of the issues or if it would be needlessly cumulative." United States v. Beech-Nut Nutrition Corp., 871 F.2d 1181, 1193 (2d Cir. 1989) (citing Fed. R. Evid. 403; United States v. Carter, 801 F.2d 78, 83 (2d Cir. 1986); United States Martinez, 775 F.2d 31, 37 (2d Cir. 1985)). Moreover, courts considering motions in limine may reserve decision until trial so that the motion is placed in the appropriate factual context. See Nat'l Union Fire Ins. Co. v. L.E. Myers Co. Group, 937 F. Supp. 276, 287 (S.D.N.Y. 1996). Alternatively, the court is "free, in the exercise of sound judicial discretion, to alter a previous in limine ruling" at trial as "the case unfolds, particularly if the actual testimony differs from what was contained in the

[movant's] proffer." Luce, 469 U.S. at 41-42. At-bar, Defendant makes four general requests seeking: (1) to be entitled to qualified immunity as a matter of law; (2) to preclude evidence regarding alleged economic damages; (3) to be permitted to inquire into the facts about two of Plaintiff's felony convictions; and (4) to bar

1 As this case is days away from trial, the Court assumes that the parties are sufficiently familiar with the relevant factual and procedural background necessary to address the issues at- bar. 2 Plaintiff from referencing a specific dollar amount regarding damages during both opening and closing statements. See Dkt. No. 32 at 5-15. As to the first request seeking qualified immunity, the Court will reserve judgment and revisit the matter following arguments and introduction of evidence at trial. The Court notes that application of qualified immunity would effectively dispose of the instant case in Defendant's favor. However, Defendant failed to file a dispositive motion prior to the deadline for doing so; hence, the Court has not had adequate opportunity to review the complete record evidence against

the parties' contentions. And while the parties have submitted certain pre-trial factual stipulations, the Court finds that, at this stage, any request for qualified immunity would be more appropriately addressed following trial testimony and evidence. See Dkt. No. 42. Accordingly, the Court will reserve judgment as to the application of qualified immunity. As to the second request seeking preclusion of evidence relative to certain economic damages, the Court will likewise reserve its ruling. Defendant's request to preclude Plaintiff "from offering any proof regarding a claim for economic damages" is simply too broad to resolve at this pre-trial stage. Dkt. No. 32 at 12. The Court notes that, under the "Prayer for Relief" section in the amended complaint, Plaintiff asserted that he seeks approximately three million

dollars, without any distinction as to economic or non-economic damages. See Dkt. No. 4 at 4. While Defendant claims that there has been no subsequent "notice" provided since Plaintiff obtained pro bono counsel, Defendant has produced no authorities suggesting that such notice is explicitly required, particularly where there exists a specific monetary demand in the pleadings. See Dkt. No. 32 at 11-12. Under the circumstances, the Court finds no reason to categorically bar Plaintiff at trial from presenting supporting evidence as to economic damages. Nonetheless, the

3 Court will reserve ruling at this time insofar as Defendant has more narrowly tailored objections to specific proposed evidence, as such issues arise during trial. As to the third request concerning the proposed admission of Plaintiff's felony convictions, the Court will deny the motion, in part, and grant the motion, in part. Rule 609 of the Federal Rules of Evidence grants broad discretion in admitting or excluding evidence of prior convictions.2 See United States v. Pedroza, 750 F.2d 187, 202 (2d Cir. 1984). "The Rule requires district courts to admit the name of the conviction, its date, and the sentence imposed unless the

district court determines that the probative value of that evidence 'is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.'" United States v. Estrada, 430 F.3d 606, 621 (2d Cir. 2005) (quotation omitted). In "balancing the probative value against prejudicial effect under [Rule 609], courts examine the following factors:

2 Rule 609(a) provides that:

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Related

Luce v. United States
469 U.S. 38 (Supreme Court, 1984)
United States v. Leroy Hayes
553 F.2d 824 (Second Circuit, 1977)
Daniels v. Loizzo
986 F. Supp. 245 (S.D. New York, 1997)
National Union Fire Insurance v. L.E. Myers Co. Group
937 F. Supp. 276 (S.D. New York, 1996)
United States v. Brown
606 F. Supp. 2d 306 (E.D. New York, 2009)
Palmieri v. Defaria
88 F.3d 136 (Second Circuit, 1996)
United States v. Estrada
430 F.3d 606 (Second Circuit, 2005)
United States v. Beech-Nut Nutrition Corp.
871 F.2d 1181 (Second Circuit, 1989)

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Bluebook (online)
Phillips v. DOCCS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phillips-v-doccs-nynd-2023.