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Sims v. Great Am. Life Ins. Co. - 469 F.3d 870 (10th Cir. 2006)


The U.S. Court of Appeals for the Tenth Circuit is persuaded that the Federal Rules of Evidence are not governed by the Erie doctrine. Concepts of federalism still guide the Court's understanding of the interplay between the Federal Rules and state law. Although the Court does not ground its holding in Erie, the Court concludes that state substantive policy directs the admissibility of evidence under the relevancy considerations of Fed. R. Evid. 401.


Lawrence Sims died when the speeding car he was driving sailed off a rural road. Prior to his untimely death, he had obtained life insurance from Great American Life Insurance Company. Sims's surviving spouse, Clara, made a claim on this policy but, after an investigation, Great American denied the claim under its non-accidental death provision concluding that Lawrence had committed suicide. Clara then filed suit against Great American alleging breach of contract and bad faith for its failure to pay her husband's life insurance policy. A jury found the death was accidental, and awarded lara $1.4 million in compensatory and punitive damages. On appeal, Great American argued that the district court made numerous evidentiary and procedural errors when it precluded Great American from introducing relevant evidence pertaining to the crash and Lawrence Sims's state of mind at the time of his death. According to Great American, the district court improperly applied state law, as opposed to the Federal Rules of Evidence, to exclude evidence showing Lawrence failed to wear his seat belt on the night he died, as well as reports and testimony from state officials concerning Lawrence Sims’s manner of death.


Was the district court required to analyze substantive state policy in considering the admissibility of evidence?




The Tenth Circuit held that the Erie doctrine did not govern the admissibility of evidence under the Federal Rules of Evidence, but the Rules still required diversity courts to analyze substantive state policy in considering admissibility. As for evidence that the decedent's non-use of a seat belt was proof of suicidal intent, the Court concluded that Okla. Stat. tit. 47, § 12-420, was not created to apply to state of mind evidence. Thus, it was error to exclude the evidence, but the error was harmless. As to the limitation on the use of the medical examiner's report and death certificate, the state rules were procedural and Fed. R. Evid. 401 should have governed the admissibility, however, there was no error as the state rule was identical to Fed. R. Evid. 702. Likewise, the Court held that although the state rules were procedural, an officer's testimony was similarly inadmissible under the Federal Rules. The suicide of decedent's father was properly excluded as irrelevant and prejudicial. The evidence did not support a bad faith claim; the claim should not have gone to the jury. There was no evidence of fraud or evil intent to support punitive damages.

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