Law School Case Brief
Fields v. City of Chi. - No. 12 C 1306, 2018 U.S. Dist. LEXIS 58395 (N.D. Ill. Apr. 5, 2018)
Trial courts have considerable discretion to manage the submission of evidence, including granting motions in limine.
Plaintiff Erick Fields brought this civil rights action pursuant to 42 U.S.C. § 1983 against defendants, including the City of Chicago, for the alleged deprivation of his constitutional rights. Fields alleged that, on February 24, 2011, he was in his garage removing a license plate from his car when defendants police officers Navez and Lomeli entered and Navez shot him in the abdomen without provocation. Fields alleged that, after he was shot, no ambulance was called, and instead defendants police officers Rivera, Guzman, and Pinal conferred with Navez and Lomeli about how to respond to the situation, delaying and obstructing Fields’ efforts to call for an ambulance and obtain medical treatment. After Fields was eventually taken to the hospital, he alleged that unknown Chicago police officers searched his home without a warrant or probable cause, leaving his home in disarray and damaging his property. Defendants dispute this account and claim that Navez feared for his life after Fields allegedly lunged toward him with a "silver object," which Navez believed to be the barrel of a gun but turned out to be a wrench.
Fields brought three claims under 42 U.S.C. § 1983 for deprivation of his constitutional rights based on defendants' alleged use of excessive force, unlawful entry into his home, and conspiracy to deprive him of his constitutional rights. Fields also brought state claims under Illinois law for battery, intentional infliction of emotional distress, and trespass.
In a civil rights action pursuant to 42 U.S.C. § 1983 for alleged deprivation of constitutional rights by city police officers, did the federal district court have discretion in granting the parties' motions in limine?
The United States District Court held that trial courts have considerable discretion to manage the submission of evidence, including granting motions in limine. In limine rulings serve to ensure the expeditious and evenhanded management of the trial proceedings. Such motions are not favored, however, and the Court should grant a motion in limine only when the evidence at issue is clearly inadmissible on all potential grounds. Under Federal Rule of Evidence 403, the Court has authority to exclude relevant evidence if its probative value 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 Court granted in part and denied in part the various motions in limine. The parties were directed to reevaluate their settlement positions in light of this opinion and to exhaust all settlement possibilities prior to trial.
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