Rita Florian Pingree v. University of Utah and Caroline Milne

CourtDistrict Court, D. Utah
DecidedFebruary 13, 2026
Docket2:20-cv-00724
StatusUnknown

This text of Rita Florian Pingree v. University of Utah and Caroline Milne (Rita Florian Pingree v. University of Utah and Caroline Milne) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rita Florian Pingree v. University of Utah and Caroline Milne, (D. Utah 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

RITA FLORIAN PINGREE, MEMORANDUM DECISION AND Plaintiff, ORDER ON MOTIONS IN LIMINE

v. Case No. 2:20-cv-00724-JNP-CMR UNIVERSITY OF UTAH and CAROLINE MILNE, Chief District Judge Jill N. Parrish

Defendants.

Before the court are Plaintiff’s and Defendants’ various motions in limine (“MILs”). The court first addresses Defendants’ motions and then addresses Plaintiff’s motions. LEGAL STANDARD “A motion in limine presents the trial court with the opportunity ‘to rule in advance of trial on the relevance of certain forecasted evidence, as to issues that are definitely set for trial, without lengthy argument at, or interruption of, the trial.’” Wilkins v. Kmart Corp., 487 F. Supp. 2d 1216, 1218 (D. Kan. Apr. 10, 2007) (quoting Palmieri v. Defaria, 88 F.3d 136, 141 (2d Cir. 1996)). “Although such pretrial rulings can save time and avoid interruptions at trial, ‘a court is almost always better situated during the actual trial to assess the value and utility of evidence. Consequently, a court should reserve its rulings for those instances when the evidence plainly is inadmissible on all potential grounds . . . and it should typically defer rulings on relevancy and unfair prejudice objections until trial when the factual context is developed[.]” Gilbert v. Dolgencorp, No. CIV-22-847-D, 2024 WL 3824804, at *1 (W.D. Okla. Aug. 14, 2024) (quoting Wilkins, 487 F. Supp. 2d at 1218) (citation modified). DEFENDANTS’ MOTIONS IN LIMINE I. MIL No. 1

Defendants’ motion in limine No. 1 seeks to exclude Plaintiff’s proposed Exhibit Nos. 40, 81, 113, 126, 127, 142, and 144. ECF No. 169. Defendants also seek to exclude testimony and argument on related due process and breach of express and implied contract claims that were dismissed. In essence, Defendants argue that because these exhibits, testimony, and argument relate to claims that are no longer part of the case, the court should “prohibit any mention of any obligation or failure on the part of Dr. Milne or the University to comply with the policies that make up these exhibits or any of the processes or practices embodied by them.” Id. at 2. In response, Plaintiff agrees to withdraw Exhibit Nos. 126 and 127. However, Plaintiff argues that Exhibit Nos. 40, 81, 113, 142, and 144 will be used to make pretext arguments, in which deviation from policies is relevant, or towards other ends. The court addresses each exhibit

in turn. Exhibit Nos. 40 and 142 (“Standards of Performance and Evaluation Policy” and “Supervision Policy”). Plaintiff argues these exhibits are relevant to the remaining claims, as they showcase what standards and obligations existed for residents, supervisors, and program directors relating to evaluations and performance. In addition, Plaintiff asserts that deviation from policies relating to performance and feedback may support a pretext argument. Defendants argue that the court has already held that these policies are inapplicable to Plaintiff because she was a preliminary intern rather than a categorical resident. Thus, they argue

2 the policies are (1) not relevant; or (2) if relevant, unduly likely to prejudice Defendants, to confuse or mislead the jury, or to waste the jury’s time. See Fed. R. Evid. 401 and 403. Defendants are correct as to the former point. With respect to Exhibit No. 40, this court held that the Standards of Performance and Evaluation Policy, created per GME 11.5 (Plaintiff

Exhibit No. 127), applied only to categorical residents. Thus, whether the processes outlined within were followed are not relevant to Plaintiff’s surviving claims. Plaintiff cannot be said to offer this policy to show “deviations from obligations” when Dr. Milne was not obligated to follow the policy with respect to Plaintiff. See Fed. R. Evid. 401 (“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.”). The same analysis applies to Exhibit No. 142. The court previously held that the Supervision Policy, created per GME 11.5 (Plaintiff Exhibit No. 127), also applied only to categorical residents. The court accordingly GRANTS the motion in limine with respect to Plaintiff’s Exhibits No. 40 and 142. The court also GRANTS the motion with respect to testimony and argument

directly relating to claims that have been dismissed. Exhibit Nos. 81 and 113 (email chains). Plaintiff argues that these exhibits are relevant to the retaliation claim timeline by demonstrating communications occurring after Plaintiff engaged in protected activity. Defendants suggest that these exhibits are included to elicit testimony referencing the dismissed claims or to continue to claim that Defendants were obligated to follow the policies in Exhibits Nos. 40, 127, 127, 142, and 144. The court finds that the email chains in Exhibit Nos. 81 and 113 are relevant to the retaliation claim when used as Plaintiff asserts. The court also does not find the email chains to be unduly prejudicial, misleading, or a waste of time under Rule 403. Fed. R. Evid. 403 (“The court may exclude relevant evidence if its probative value 3 is substantially outweighed by a danger of unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.”). The emails do not refer directly to the contested policies and could reasonably be used to establish a timeline with respect to the retaliation claim. The court accordingly DENIES the motion in limine with respect

to Plaintiff’s Exhibit Nos. 81 and 113. Exhibit No. 144 (“University Non-discrimination Policy”). Plaintiff asserts this exhibit is relevant to a potential pretext argument. The court agrees. Defendants’ argument that the court found certain policies inapplicable to Plaintiff does not extend to the non-discrimination policy, which the court noted was applicable university-wide. The court accordingly DENIES the motion in limine with respect to Exhibit No. 144. II. MIL No. 2 Defendants’ motion in limine No. 2 seeks to exclude from trial any evidence, testimony, reference, or argument related to Plaintiff’s proposed Exhibit No. 2 (“Unsigned Resident Charts”). ECF No. 170. Defendants argue that the exhibit is completely irrelevant to Plaintiff’s remaining

claims. Specifically, they argue that the unsigned resident chart was no longer sent to Dr. Milne by the time of Plaintiff’s intern year, that the chart focuses only on unsigned charts, rather than the failure to write discharge summaries as Plaintiff is alleged to have done, and that the chart only applies to residents, not preliminary interns. Plaintiff responds that the chart is relevant to her claim that criticism about her alleged failure to submit discharge summaries was pretextual—other individuals had “document deficiencies that went unaddressed for months.” ECF No. 204 at 2. While it may not be a one-to-one comparator, the court finds that the chart is nevertheless relevant to the pretext argument. See Smothers v. Solvay Chemicals, Inc., 740 F.3d 530, 541 (10th Cir. 2014) (“When comparing different treatment of similarly-situated employees, ‘the comparison 4 need not be based on identical violations of identical work rules; the violations need only be of comparable seriousness.’”).

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Rita Florian Pingree v. University of Utah and Caroline Milne, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rita-florian-pingree-v-university-of-utah-and-caroline-milne-utd-2026.