William Bernal v. Sacramento County Sheriff Department, et al.

District Court, E.D. California·Decided February 20, 2026·No. 2:19-cv-00482·Unknown

Opinion

1 2 3 4 5 6 7 10 11 WILLIAM BERNAL, No. 2:19-cv-00482-DC-AC 12 Plaintiff, 13 v. ORDER ON MOTIONS IN LIMINE 14 SACRAMENTO COUNTY SHERIFF (Doc. Nos. 100, 102) DEPARTMENT, et al., 15 Defendants. 16

17 18 This matter is set for trial on April 13, 2026. On July 14, 2025, Defendants Chhlang and 19 Bliss filed six motions in limine. (Doc. Nos. 99–104.) The following day, Plaintiff William 20 Bernal filed one motion in limine. (Doc. No. 111.) The parties filed oppositions to the motions, 21 and Defendants filed replies in support of their motions. (Doc. Nos. 112–18, 121–126.) 22 On October 10, 2025, the court held a hearing on the parties’ motions in limine. (Doc. No. 23 128.) At that hearing, the court ruled on five of the parties’ motions in limine. (Id.) The court 24 ordered the parties to provide supplemental briefing on Defendants’ motion in limine No. 4 to 25 address whether Plaintiff’s state law claim for false imprisonment was still at issue in the case. 26 (Id.) On October 24 and 25, 2025, the parties timely filed supplemental briefing as ordered by the 27 court (Doc. Nos. 129–30), and the court took under submission Defendants’ motions in limine 28 Nos. 2 and 4. 1 Defendants’ motion in limine No. 2 seeks to exclude and/or limit testimony from 2 Plaintiff’s treating physicians/providers related to causation of Plaintiff’s injuries. (Doc. No. 100.) 3 Defendants’ motion in limine No. 4 seeks to exclude testimony from Plaintiff and/or others 4 related to the legality of the detention. (Doc. No. 102.) For the reasons explained below, the court 5 will grant in part and deny in part Defendants’ motion in limine No. 2 and grant Defendants’ 6 motion in limine No. 4. 8 “A motion in limine is a procedural mechanism to limit in advance testimony or evidence 9 in a particular area.” United States v. Heller, 551 F.3d 1108, 1111 (9th Cir. 2009) (citing Black’s 10 Law Dictionary 803, 1038–39 (8th ed. 2004)). Like other pretrial motions, motions in limine “are 11 useful tools to resolve issues which would otherwise clutter up the trial.” City of Pomona v. SQM 12 N. Am. Corp., 866 F.3d 1060, 1070 (9th Cir. 2017) (quoting Palmerin v. City of Riverside, 794 13 F.2d 1409, 1413 (9th Cir. 1986)). “Although the Federal Rules of Evidence do not explicitly 14 authorize in limine rulings, the practice has developed pursuant to the district court’s inherent 15 authority to manage the course of trials.” Luce v. United States, 469 U.S. 38, 41 n.4 (1984) 16 (citations omitted). 17 “In many instances, rulings ‘should be deferred until trial, so that questions of foundation, 18 relevancy, and potential prejudice may be resolved in proper context.’” Vargas v. Lopez, No. 23- 19 cv-02490-TSH, 2025 WL 2800196, at *1 (N.D. Cal. Sep. 30, 2025) (quoting United States v. Pac. 20 Gas & Elec. Co., 178 F. Supp. 3d 927, 941 (N.D. Cal. 2016)); see Williams v. Castro, No. 20-cv- 21 01617-SAB, 2023 WL 2432770, at *1 (E.D. Cal. Mar. 9, 2023) (noting that “some evidentiary 22 issues are not accurately and efficiently evaluated by the trial judge in a motion in limine and it is 23 necessary to defer ruling until during trial when the trial judge can better estimate the impact of 24 the evidence on the jury.”) (citing Jonasson v. Lutheran Child and Family Servs., 115 F.3d 436, 25 440 (7th Cir. 1997)). 26 Moreover, in limine rulings are not binding on the court, and the “district court may 27 change its ruling at trial because testimony may bring facts to the district court’s attention that it 28 did not anticipate at the time of its initial ruling.” City of Pomona, 866 F.3d at 1070 (quoting 1 United States v. Bensimon, 172 F.3d 1121, 1127 (9th Cir. 1999)). 2 A. Defendants’ Motion in Limine No. 2 3 1. Relevant Procedural Background 4 Plaintiff William Bernal filed the initial complaint initiating this civil rights action on 5 March 15, 2019.1 (Doc. No. 1.) A few days later, the court issued a scheduling order, which 6 provided the following regarding the disclosure of expert witnesses: 7 All counsel are to designate in writing, and serve upon all other parties the name, address, and area of expertise of each expert that 8 they propose to tender at trial not later than sixty (60) days after the close of discovery. The designation shall be accompanied by a 9 written report prepared and signed by the witness. The report shall comply with Federal Rule of Civil Procedure 26(a)(2)(B). 10 Within thirty (30) days after the designation of expert witnesses, any 11 party may designate a supplemental list of expert witnesses who will express an opinion on a subject covered by an expert designated by 12 an adverse party. The right to designate a supplemental expert for rebuttal purposes only shall apply to a party who has not previously 13 disclosed an expert witness on the date set for expert witness disclosure by this Order. 14 Failure of a party to comply with the disclosure schedule as set forth 15 above in all likelihood will preclude that party from calling the expert witness at the time of trial. An expert witness not appearing on the 16 designation will not be permitted to testify unless the party offering the witness demonstrates: (a) good cause for the party’s failure to 17 designate the expert witness in accordance with this Order; (b) that the Court and opposing counsel were promptly notified upon 18 discovery of the witness; and (c) that the witness was promptly made available for deposition. 19 For purposes of this Order, an “expert” is any person who may be 20 used at trial to present evidence under Federal Rules of Evidence 702, 703, and 705, which include both “percipient experts” (persons 21 who, because of their expertise, have rendered expert opinions in the normal course of their work duties or observations pertinent to the 22 issues in the case) and “retained experts” (persons specifically designated by a party to be a testifying expert for the purposes of 23 litigation). 24 Each party shall identify whether a disclosed expert is percipient, retained, or both . . . . 25 26 1 Plaintiff initiated this action with his wife, Celia Bernal. (Doc. No. 1.) The court ruled on and 27 dismissed Celia Bernal’s claims. (See Doc. Nos. 32, 65.) Because the pending motions in limine pertain only to Plaintiff, the court does not recite the procedural history relating to Celia Bernal’s 28 claims in this order. 1 Counsel are instructed to complete all discovery of expert witnesses in a timely manner in order to comply with the Court’s deadline for 2 filing dispositive motions. 3 (Doc. No. 4 at 3–4.) 4 On November 24, 2019, Plaintiff filed his first amended complaint. (Doc. No. 11.) On 5 March 12, 2020, the court modified the scheduling order pursuant to a stipulation by the parties 6 and extended the expert disclosure deadline to December 4, 2020, the supplemental expert 7 disclosures deadline to January 4, 2021, and the deadline for completing expert discovery to 8 February 3, 2021. (Doc. No.

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