Jones v. Perez-Pantoja

Background

The court heard the parties’ motions in limine—requests to decide before trial whether particular evidence may be presented—on August 8, 2024. The remaining claims concern whether defendants Turingan and Perez-Pantoja retaliated against Amos Jones in violation of the First Amendment when: (1) Turingan allegedly refused to let Jones perform his porter work assignment in August 2020; (2) Perez-Pantoja allegedly ordered Jones to “lock up” on May 20, 2021; and (3) Turingan allegedly searched and damaged Jones’s cell and confiscated his earphones on July 10, 2021.

Joint Motions in Limine

The court granted the parties’ request to exclude evidence that the State of California might pay a judgment or reimburse defendants. The court found that information about indemnification was not relevant to Jones’s claims and could unfairly encourage a verdict against defendants.

The court granted the request to exclude evidence of Jones’s prior complaints, lawsuits, and administrative grievances. If Jones opened the door by testifying about his history of filing grievances, defendants could introduce rebuttal evidence about those prior complaints.

The court also granted the request to exclude evidence of Jones’s prison disciplinary record and alleged gang affiliation. The court found the disciplinary record irrelevant, unfairly prejudicial, improper character evidence, and inadmissible hearsay. It found gang-affiliation evidence highly prejudicial. The court allowed possible use of such evidence for rebuttal or impeachment if Jones opened the door, including if he claimed to be a “model inmate” or denied gang affiliation.

The court granted the request to exclude evidence of other inmates’ lawsuits, grievances, or allegations concerning defendants. It found that those matters were irrelevant to the claims being tried and risked unfair prejudice and distraction.

The court granted the request to bifurcate, or separate, the punitive-damages issue. If the jury found for Jones and found him entitled to punitive damages, the same jury would then decide the amount.

The parties stipulated that limited shackling was warranted because of Jones’s violent criminal history and lengthy sentence. The court granted that request after making the required individualized security determination. To reduce possible prejudice, the court directed that counsel tables be covered with tablecloths and ordered that Jones be allowed to wear civilian clothes during trial. Jones’s counsel would be responsible for bringing those clothes to the United States Marshal Service each morning.

Jones’s Motion Regarding Prior Convictions

Jones moved to exclude evidence of his 2002 criminal convictions under Rules 402, 403, and 609 of the Federal Rules of Evidence. Defendants argued that they should be allowed to identify four felony convictions without stating the specific crimes.

The court granted Jones’s motion. It found that the convictions’ prejudicial effect substantially outweighed their value and that the convictions were not relevant to this civil action involving alleged First Amendment retaliation. Neither side may introduce evidence of Jones’s prior convictions.

Defendants’ Motion Regarding Work-Assignment Evidence

Defendants moved to exclude evidence that they prevented Jones from participating in his work assignment except during August 2020 and on May 20, 2021. They argued that evidence about a longer period could improperly expand the case, confuse the jury, increase trial time, and force them to defend against a broader alleged conspiracy.

The court denied defendants’ motion. Jones agreed that the legal claims were limited to the three incidents identified above, but the court explained that admissible evidence is not limited to facts alleged as separate claims. Evidence about other days could help show whether defendants prohibited or allowed Jones to work on the specific dates at issue. Evidence from the period between August 2020 and July 2021 could also bear on defendants’ intent, the connection among the claims, the credibility of witnesses, and the accuracy of the alleged incidents.

The court further found that defendants’ motion lacked clear limits or a workable method for deciding what evidence to exclude. It concluded that particular objections could be addressed during trial and that the evidence’s value was not outweighed by unfair prejudice, delay, or confusion.

Disposition

The court granted the parties’ joint motions on the specified evidentiary issues, granted Jones’s motion to exclude his prior convictions, and denied defendants’ motion concerning work-assignment evidence.