Stephen (Rex) Sanders, et al. v. Bay Area Air Quality Management District

CourtDistrict Court, N.D. California
DecidedFebruary 3, 2026
Docket3:23-cv-04416
StatusUnknown

This text of Stephen (Rex) Sanders, et al. v. Bay Area Air Quality Management District (Stephen (Rex) Sanders, et al. v. Bay Area Air Quality Management District) 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
Stephen (Rex) Sanders, et al. v. Bay Area Air Quality Management District, (N.D. Cal. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

STEPHEN (REX) SANDERS, et al., Case No. 23-cv-04416-RFL

Plaintiffs, ORDER REGARDING MOTIONS IN v. LIMINE AND PRETRIAL MATTERS

BAY AREA AIR QUALITY Re: Dkt. Nos. 196, 202–07, 209–12, 215– MANAGEMENT DISTRICT, 34, 236–37 Defendant.

I. PLAINTIFFS’ MOTIONS IN LIMINE MIL No. 1 re Hearsay in Expert Reports. Granted in part and denied in part. Regarding Ms. Silva’s reliance on statements of other witnesses, she is precluded from offering statements of witnesses that have not already been introduced in the trial, other than the statements of Plaintiffs, unless those statements are first discussed out of the presence of the jury. Even assuming those statements are commonly relied upon by HR practices experts, recounting hearsay statements from percipient witnesses is likely not to be helpful to the jury and is likely more prejudicial than probative under Rule 403. The remainder of Plaintiffs’ motion is denied. Regarding Dr. Strassberg’s use of Sanders’s medical records, some portions would be within Rule 803(4)’s hearsay exception, and some other portions might be helpful information for the jury of the type that a medical expert would reasonably rely upon and could independently analyze within Rule 703. It is impossible to assess this motion on a pretrial basis without greater specificity regarding the portions requested to be precluded. Regarding Ms. Silva’s analysis of the Audit report, the report is non-hearsay admitted for the effect on the listener: that is, the decisionmakers who decided to terminate Plaintiffs. If Plaintiffs wish to propose a limiting instruction, they may meet and confer with Defendant and propose one at least one court day before it is to be read. There may be portions of the report that are more prejudicial than probative under Rule 403, but Plaintiffs do not specify which portions are being challenged on that basis. Regarding Ms. Silva’s reference to the notices of Plaintiffs’ intended termination, those are non-hearsay verbal acts and also within Rule 803(3)’s hearsay exception for statements of then-existing intention. The termination notices are important evidence of the District’s stated basis for terminating Plaintiffs and are not properly precluded under Rule 403. The parties shall meet and confer about any specific portions of the medical records and Audit report that Plaintiffs believe should be redacted under Rule 403 or as inadmissible hearsay, and raise any disputes with the Court via a joint filing setting forth their respective positions submitted by February 10, 2026. MIL No. 2 re Granted. As Defendant concedes, references to Sanders’s are properly precluded. That has no relevance to the case. As to Sanders’s statements to Dr. Hirchak that is of very limited probative value. Sanders has already admitted in deposition that he had multiple co-stressors, including his father’s death from COVID, his move, and family stressors. Sanders may be asked generally

that could open the door to this topic. If Defendant believes that has occurred, it must first raise the issue out of the presence of the jury before asking questions or introducing evidence on the topic. MIL No. 3 re Text Messages: Denied as insufficiently specific. Plaintiffs do not identify which text messages are challenged or provide any information about them. The parties shall meet and confer about the specific text messages to which Plaintiff objects, and shall raise any disputes with the Court via a joint filing setting forth their respective positions submitted by February 10, 2026. MIL No. 4 re Bachmann Litigation: Granted in part and denied in part. Defendant may introduce evidence that Sanders and Levels knew that the District had been sued for destroying documents that were alleged to have been required to be kept under the law, and that Sanders and Levels nonetheless shredded documents without inventorying them after the suit. That information is relevant because the District cites the shredding incident as a legitimate non- discriminatory reason for their termination. At the pretrial conference, Plaintiffs argued that they were not in fact legally required to inventory or prohibited from shredding the documents. Regardless, though, that evidence is probative of whether (a) the District had reason to be extra- cautious about shredding documents after the lawsuit, (b) Sanders and Levels’s failure to inventory and decision to shred documents was insufficiently cautious, and (c) the ultimate decisionmakers would have terminated Sanders and Levels for their actions. It is not necessary to introduce evidence of the details of the lawsuit, that it settled or for what amount, or that Sanders was a defendant in the suit, as all of that information is of minimal relevance, and is unfairly prejudicial because it suggests wrongdoing by Sanders as to the complained-of actions, which are undisputedly irrelevant to his termination, and is a waste of time. MIL No. 5 re Internal Grievance Procedures and DFEH/EEOC Investigation: Denied as to the internal grievance procedure. Plaintiffs’ decision not to pursue an appeal is highly pertinent to mitigation for the reasons identified in Rosenfeld v. Abraham Joshua Heschel Day Sch., Inc., 226 Cal. App. 4th 886, 901 (2014). At the pretrial conference, Plaintiffs’ counsel argued that the avoidable consequences doctrine described by Rosenfeld was limited to cases where “no tangible employment action” was taken, pointing to language in State Dep’t of Health Servs. v. Superior Ct., 31 Cal. 4th 1026, 1035 (2003). However, that language did not purport to limit the avoidable consequences doctrine to cases without a tangible employment action but instead provided that the doctrine applies equally to such situations. Indeed, State Dep’t of Health Servs. involved a constructive termination. Id. at 1035. Accordingly, the Court declines to limit the avoidable consequences doctrine to cases where no tangible employment action was taken. Granted as to the DFEH/EEOC investigation, because Plaintiffs’ decision to seek relief from the court rather than the administrative agencies is not relevant to mitigation and has nothing to do with the adequacy of Defendant’s investigation into Plaintiffs’ allegations. MIL No. 6 re Alleged Shredding of Documents in Broadbent’s Office: Denied. As noted above re MIL No. 4, the alleged incident is directly relevant to the District’s asserted non- discriminatory reason for termination, and thus its probative value outweighs the danger of unfair prejudice. MIL No. 7 re Undisclosed Witnesses: Denied as to Hopkins and Larson, who were both disclosed. If Plaintiffs believed the disclosure was insufficiently specific, they should have moved to compel discovery at an earlier juncture. Denied as to Hinojosa, because his role was disclosed when Defendant stated he was the “person most knowledgeable” about these topics prior to the close of discovery, so the failure to disclose was harmless. However, like any witness, Hinojosa may testify only to events within his personal knowledge. Granted as to Baker. There is no evidence that Baker was ever disclosed, and Levels’s personal friendship with Baker and Baker’s role as the current HR Director is insufficient to disclose that the District believed she had knowledge about information relevant to this litigation. Accordingly, the failure to disclose was not harmless. Granted as to Hope Cahan. (See Dkt. No. 247.) Defendant does not demonstrate cause for their late disclosure. This belated disclosure was not harmless because Plaintiffs did not have an opportunity to depose her, as they did not know that Defendant intended to rely on her testimony. MIL No. 8 re Reasons for Termination of Illumyx Project: Granted in part and denied in part.

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Related

State Department of Health Services v. Superior Court
79 P.3d 556 (California Supreme Court, 2003)
Rosenfeld v. Abraham Joshua Heschel Day School, Inc.
226 Cal. App. 4th 886 (California Court of Appeal, 2014)

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Bluebook (online)
Stephen (Rex) Sanders, et al. v. Bay Area Air Quality Management District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephen-rex-sanders-et-al-v-bay-area-air-quality-management-district-cand-2026.