Planned Parenthood Federation of America, Inc. v. Center for Medical Progress

CourtDistrict Court, N.D. California
DecidedSeptember 12, 2019
Docket3:16-cv-00236
StatusUnknown

This text of Planned Parenthood Federation of America, Inc. v. Center for Medical Progress (Planned Parenthood Federation of America, Inc. v. Center for Medical Progress) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Planned Parenthood Federation of America, Inc. v. Center for Medical Progress, (N.D. Cal. 2019).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 PLANNED PARENTHOOD Case No. 16-cv-00236-WHO FEDERATION OF AMERICA, INC., et al., 8 Plaintiffs, ORDER ON PRETRIAL MOTIONS 9 v. Re: Dkt. Nos. 740, 754, 758, 761, 762, 764, 10 CENTER FOR MEDICAL PROGRESS, et 789 11 al., Defendants. 12 13 On September 9, 2019, I heard argument on the parties’ motions in limine, motions to 14 exclude, and disputed legal issues. A few overarching issues will be addressed first, to provide 15 necessary context and explanation for the specific rulings laid out below. 16 Journalism vs. a Smear Campaign. These are the dueling narratives of this case. 17 Defendants argue that they were involved in traditional under-cover journalism in order to expose 18 violations of the law by Planned Parenthood with respect to PPFA and its affiliates’ fetal tissue 19 transfer programs. Plaintiffs argue that the goal of defendants’ Human Capital Project (HCP) was 20 to smear plaintiffs with allegations they profited from the fetal tissue transfer programs in order to 21 drive PPFA and its affiliates out of business. These narratives are not directly and significantly 22 relevant to the remaining claims and defenses in this case that are to be decided by the jury. 23 However, they are central to the context of and the background to this case. Therefore, defendants 24 are entitled to characterize their conduct as a journalistic enterprise and plaintiffs are entitled to 25 attack that in part by exploring defendants’ past conduct and writings regarding abortion. 26 Illegal Conduct. The causes of action in this case concern whether the strategies chosen by 27 the defendants with respect to the Human Capital Project broke the law and caused damage 1 conduct, whether 4 of 59 Planned Parenthood affiliates profited from selling fetal tissue, whether 2 there have been any live births during abortion procedures at Planned Parenthood affiliates, and 3 how government entities have responded to the HCP disclosures. Those debates are barely, if at 4 all, relevant to the causes of action that will be tried to the jury. Evidence on those issues will be 5 excluded under Federal Rule of Evidence 403 because it will confuse the jury about the issues it 6 needs to decide, waste a significant amount of trial time, and be prejudicial. 7 The defense argues that illegality by plaintiffs in their fetal tissue programs is critically 8 related to their intent (under the federal wiretapping claim), to the reasonable expectations of 9 privacy in recorded conversations, to the newsworthiness of defendants’ publications, and to the 10 social utility of defendants’ conduct. Plaintiffs have dropped their invasion of privacy claims and 11 publication of private facts hook for the federal wiretapping claim, so newsworthiness and social 12 utility are no longer relevant to the claims and defenses to be decided by the jury.1 Similarly, 13 while defendants’ intent to violate RICO remains an element of the federal wiretapping claim, that 14 intent must be established based on evidence defendants knew at the time of the inception of the 15 HCP and prior to the first surreptitious recording. Defendants can present evidence of what they 16 knew, what they believed, and how they carried out their journalistic endeavors through the HCP 17 (the defense narrative discussed above) consistent with their intent. What defendants uncovered 18 through the surreptitious recordings or through discovery in this case, and any expert opinion on 19 that evidence, is not relevant. 20 Because the California Penal Code section 633.5 “reasonable belief” defense is an issue 21 that will be decided by the jury – as relevant only to plaintiffs’ Penal Code section 632 and 634 22 illegal recording and trespass claims – defendants Daleiden and Merritt may present evidence of 23 what they knew or believed regarding plaintiffs’ commission of violent felonies. That knowledge 24 or belief must be based on what Daleiden or Merritt knew prior to their first surreptitious 25 recording. Evidence regarding what Daleiden or Merritt learned following their first surreptitious 26 recording cannot be relied on for this defense. 27 1 Evidence of possibly illegal conduct does not get into this case through the issue of 2 reasonable expectation of privacy under the recording claims. Defendants argue that precluding 3 this evidence will:

4 hamstring Defendants’ ability to argue that the individuals they recorded lacked any expectation of privacy as understood by the 5 federal, Florida, and Maryland recording statutes. Defendants’ experts will need to explain how certain medical procedures work in 6 order to explain how the individuals recorded knew they were discussing wrongful conduct. See Brugmann v. State, 117 So. 3d 39, 7 49 (Fla. Dist. Ct. App. 2013) (identifying eight-factor test for determining reasonableness of expectation of privacy, including 8 illegal conduct, intent, and content of communication, upon collecting cases). 9 Dkt. No. 772 at 11. But they fail, as they did on summary judgment, to specifically identify any 10 much less each of the particular and actionable recordings that show plaintiffs’ staff members 11 discussing illegal conduct. To the extent that one or two of the actionable recordings might show 12 plaintiffs’ staff members expressing interest or theoretical ability to engage in conduct that 13 defendants contend is illegal (but plaintiffs contend is not), the evidence and opinions defendants 14 seek to bring in (mostly through their proposed experts as discussed in more depth below) is vastly 15 outweighed by the Rule 403 considerations identified above. 16 Finally, the accounting issues regarding the fetal tissue programs of the four affiliate- 17 plaintiffs is not directly and significantly relevant to the remaining claims and defenses in this 18 case. Delving into these contested but minimally relevant issues, such as the proper interpretation 19 of 42 U.S.C. § 289g-2 and whether indirect costs can be considered in evaluating compliance with 20 the statute, is significantly outweighed by a number of Rule 403 factors, including juror confusion 21 and waste of time. 22 In short, compliance with or alleged violation of federal laws (including but not limited to 23 42 U.S.C. § 289g-2 and the Partial Birth Abortion Ban) and whether babies were born alive at 24 Planned Parenthood clinics to facilitate the affiliates’ participation in fetal tissue donation 25 programs will be excluded under Rule 403. I will draft a limiting instruction, to be provided for 26 counsel’s review prior to the final Pretrial Conference on September 23, 2019, explaining that the 27 truth of the allegations made in the HCP videos regarding whether plaintiffs profited from the sale 1 of fetal tissue or otherwise violated the law in securing tissue for those programs are not matters 2 for the jury to decide. 3 Newsworthiness. The newsworthiness of defendants’ HCP, including the campaign and 4 the videos, is no longer an issue for determination by the jury given that plaintiffs have dropped 5 their invasion of privacy claims (Counts 13 and 14) and dropped the “publication of private facts” 6 tort as a basis for liability under the federal wiretapping claim (Count 2). That does not preclude 7 defendants from offering evidence that they believed at the commencement of the HCP that it 8 would result in newsworthy information, or that in fact it generated attention in the media. 9 However, the stories themselves will not be admissible under Rule 403.

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Related

Brugmann v. State
117 So. 3d 39 (District Court of Appeal of Florida, 2013)

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Bluebook (online)
Planned Parenthood Federation of America, Inc. v. Center for Medical Progress, Counsel Stack Legal Research, https://law.counselstack.com/opinion/planned-parenthood-federation-of-america-inc-v-center-for-medical-cand-2019.