Mahlandt v. Wild Canid Survival & Research Ctr., Inc.

588 F.2d 626 (8th Cir. 1978)



While all proffered admissible evidence may prejudice the other party, Fed. R. Evid. 403 provides for the exclusion of relevant evidence if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by consideration of undue delay, waste of time, or needless presentation of cumulative evidence. 


The case involved a civil action for damages arising out of an alleged attack by a wolf on a child. The focus on appeal was the correctness of three rulings that excluded conclusionary statements against interest. Two of them were made by a defendant, who was also an employee of the corporate defendant. The third was in the form of a statement appearing in the records of a board meeting of the corporate defendant.


Were the statements of the employee of the corporation, as well as those appearing in the records of a board meeting of the corporation admissible against the corporation?




The court ruled that relevant evidence was usually prejudicial to the cause of the side against which it was presented, and that the prejudice which concerned the court was unreasonable prejudice. The court held that Fed. R. Evid. 403 did not warrant the exclusion of the evidence of defendant employee statements as against himself or defendant corporation.

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