Rodriguez v. Señor Frog's De La Isla, Inc. - 642 F.3d 28 (1st Cir. 2011)

Rule:

Fact stipulations speed up the trial process by eliminating the need for proving essentially uncontested facts, which helps preserve precious judicial resources. So, obviously, stipulations are valued by litigants and judges alike, and once freely-made they bind the parties, the trial court, and the appellate court too. 

Facts:

Paloma Rodríguez hit a pothole — a collision that cost her two tires and killed the engine. Turning her hazards on, Rodríguez somehow got her car to the side of the road, completely out of the way of oncoming traffic. A police officer patrolling that stretch of highway spotted her and pulled over. He left the cruiser's flashing lights on. A tow-truck driver also showed up, parked his truck in front of Rodríguez's car, activated the truck's flashing lights, pointed a spotlight on the work area, and put out cones to caution drivers passing by. As the truck driver lowered the truck's platform, Rodríguez got back into the Mazda either to grab some personal items or to do something to help out with the towing process.

That is when Carlos Estrada closed in, speeding in a Mitsubishi Mirage registered to Señor Frog. His headlights were off. He had a blood-alcohol level nearly double the legal limit in Puerto Rico. And he smashed that Mitsubishi right into the rear of Rodríguez's Mazda. Rodríguez was hurt, and apparently hurt badly. "She was thrown inside the vehicle," the officer later said. Covered in blood, she had no vital signs — "she appeared to be dead." But she survived and sued Señor Frog in district court under diversity jurisdiction, alleging negligence and negligent entrustment. In a diversity-based personal-injury case, a jury returned a $450,000 verdict for Rodriguez against Señor Frog in the U.S. District Court for the District of Puerto Rico. Señor Frog appealed, challenging nearly every aspect of the district judge's performance. Señor Frog criticized an in limine ruling barring evidence that Estrada had owned the car and that Rodriguez had downed a couple of beers hours before the crash. 

Issue:

Did the judge err in his in limine ruling barring evidence that Estrada had owned the Mitsubishi and that Rodríguez had downed a couple of beers hours before the crash?

Answer:

No

Conclusion:

The court held that Señor Frog had stipulated that it owned the car at the time of the collision. The proffered evidence concerning Rodriguez’ beer drinking depended on a chain of inferences far too strained and uncertain to have much probative worth, and certainly not enough to counterbalance its high potential for unfair prejudice. Because Señor Frog failed to provide the appellate court with a transcript of the instructions that were read to the jury, it could not prevail on its claim that a comparative-negligence instruction should have been given. Even so, there was no evidence supporting such an instruction. Similarly, because Señor Frog had not presented a transcript of the judge's final charge, it lost its claim based on the motorist's counsel's comments on damages.