Self Storage Advisors, LLC v. SE Boise Boat & RV Storage LLC

District Court, D. Idaho·Decided April 2, 2021·No. 1:18-cv-00294·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

SELF STORAGE ADVISORS, LLC, a Washington Limited Liability Case No. 1:18-cv-00294-BLW Company, MEMORANDUM DECISION AND ORDER Plaintiff,

v.

SE BOISE BOAT & RV STORAGE, LLC, an Idaho Limited Liability Company,

Defendant.

INTRODUCTION Before the Court are several motions in limine by the parties, as well as several motions for reconsideration regarding the Court’s prior rulings. See Dkts. 79, 80, 81, 82, 95. The motions have been fully briefed and are ripe for consideration. BACKGROUND A bench trial for this matter is set for April 5, 2021. The parties have agreed to waive the demand for jury trial. Dkt. 105. Self Storage Advisors, LLC (“SSA”) has sued SE Boise Boat & RV Storage (“BBRV”) for breach of contract, based on a Property Management Agreement signed by the parties in which SSA agreed to

manage the operation of BBRV’s storage facility. See Amend. Compl., Dkt. 5 at ¶ 11; Answer, Dkt. 18 at ¶ 11. SSA seeks damages in the form of lost management fees. Dkt. 5 at ¶ 43.

LEGAL STANDARD There is no express authority for motions in limine in the Federal Rules of Evidence. Nevertheless, these motions are well recognized in practice and by case law. See, e.g., Ohler v. United States, 529 U.S. 753, 758 (2000). The key function

of a motion in limine is to “exclude anticipated prejudicial evidence before the evidence is actually offered.” Luce v. United States, 469 U.S. 38, 40 n.2 (1984). A ruling on a motion in limine is essentially a preliminary ruling, which may be reconsidered in the context of trial. Id. at 41.

Motions in limine are beneficial tools that promote judicial efficiency by presenting the Court with an opportunity “to rule in advance of trial on the relevance of certain forecasted evidence . . . without lengthy argument at, or

interruption of, the trial.” D.A., 2013 WL 12147769, at *2 (quoting Palmieri v. Defaria, 88 F.3d 136, 141 (2d Cir. 1996)). But these pretrial evidentiary rulings are made before the court has seen or heard the challenged evidence, and they restrict a party’s presentation of their case. Id. Thus, “courts have recognized that motions in limine should be granted sparingly and only in those instances when the evidence plainly is inadmissible on all potential grounds.” Id. (internal quotation marks and

citation omitted). In resolving these motions, the Court is guided by Federal Rules of Evidence 401 and 403. The Court must evaluate whether the proposed evidence is relevant—

that is—whether the evidence has “any tendency to make a fact more or less probable than it would be without the evidence” and whether “the fact is of consequence in determining the action.” Fed. R. Evid. 401. Even if the evidence is relevant, the Court may exclude it 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.

ANALYSIS A. Defendant’s Reserved Motions in Limine Defendant previously filed several motions in limine but reserved them for later resolution. See Dkt. 67. Defendant has now re-raised those motions.1 Dkt. 95. 1. Defendant’s Motion in Limine No. 8 re: Payments to Corinne Graham

1 Defendant filed a Notice Striking Certain Motions in Limine. Dkt. 117. The only reserved motions remaining before the Court are the motions numbered 8 and 13. BBRV asks the Court to exclude any evidence of services provided by Corinne Graham in her capacity as an architect or engineer in support of the

construction project, on the grounds that it would be prejudicial under Federal Rule of Evidence 403. See Dkt 59-1 at 18-19. SSA agrees that this evidence is not relevant to the case, as currently anticipated. The Court is mindful, however, that

evidence which seemed irrelevant or precluded by Rule 403 in advance of trial may become very relevant after the trial begins and the dynamic of the trial unfolds differently than the Court could anticipate. For that reason, the evidence will be precluded for now, but without prejudice to a motion to reconsider by SSA should

circumstances at trial justify such a motion. 2. Defendant’s Motion in Limine No. 13 re: Hearsay BBRV next asks the Court to instruct Jay Graham that hearsay testimony is inadmissible at trial. Dkt. 59-1 at 20. BBRV argues that Graham “has manifested

an inclination to resort to hearsay testimony and should be instructed in advance that such testimony is inadmissible under our rules.” Dkt. 61 at 10. The Court declines to issue an order specifically instructing one witness that hearsay

testimony is inadmissible. The rules of evidence are equally applicable to all parties and witnesses. Any hearsay evidence that is sought to be admitted can be dealt with accordingly by the Court at trial. B. Defendant’s Supplemental Motion re: Prior Ruling Regarding Revised Property Management Agreement BBRV argues that the Court should reconsider its prior ruling excluding evidence surrounding the creation and existence of the revised property

management agreement. Dkt. 95; see also Memorandum Decision and Order, Dkt. 78 at 11-12. In responding to SSA’s third motion in limine, BBRV initially failed to adequately explain how the revised PMA was relevant to any of its affirmative

defenses. See Memorandum Decision and Order, Dkt. 78 at 11-12. BBRV has done so now. First, the Court finds that BBRV has substantially complied with the

requirements of Idaho Local District Civil Rule 7.1 in its brief, Dkt. 95, which contains one paragraph addressing previously reserved motions and uses the rest of the brief to address the motion to reconsider. The Court declines to exercise its discretion under Rule 7.1(e) to deem BBRV’s motion to be waived.

Turning to the merits of BBRV’s motion, the Court is persuaded that the circumstances surrounding the revised property management agreement may be relevant to BBRV’s seventh affirmative defense that “Plaintiff’s claims are barred

by breach of contract.” Dkt 18 at 9. The revised agreement may also be relevant to BBRV’s argument that SSA breached its express and implied obligations under the contract, and to BBRV’s argument that “SSA did not perform its contract obligations in good faith and fair dealing.” Dkt. 113 at 5. While the probative value of that evidence may be quite limited, the parties’ decision to waive their right to a jury trial removes the concern that its probative value may be outweighed

by any confusion it may create and delay it may cause. Fed. R. Evid. 403. SSA’s claim that BBRV forfeited the right to claim material breach by “disregard[ing] the provision of the operative Property Management Agreement

governing termination,” see Dkt. 97 at 5, is an issue to be determined at trial.

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Self Storage Advisors, LLC v. SE Boise Boat & RV Storage LLC, (D. Idaho 2021).

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Related

Luce v. United States
469 U.S. 38 (Supreme Court, 1984)
Ohler v. United States
529 U.S. 753 (Supreme Court, 2000)
Palmieri v. Defaria
88 F.3d 136 (Second Circuit, 1996)