Doe v. Mt. Diablo Unified School District

Background

The order addresses motions in limine, which are requests to decide before trial whether particular evidence or arguments may be presented. The court noted that such rulings may be revised at trial.

School District’s Motions

The court denied the district’s Motion in Limine No. 1, which sought to exclude inflammatory references and post-incident opinions. The court said it would intervene at trial if witnesses or attorneys used inappropriate language concerning Mr. Gonzalez.

The court denied Motion No. 2, which sought to exclude references to other claims or lawsuits. The district had not identified the cases or incidents it wanted excluded, so the court would not issue a blanket ruling at that stage.

The court denied Motion No. 3, which sought to exclude references to Jane Doe as “disabled” or having “special needs.”

The court denied Motion No. 4, which sought to exclude evidence of complaints about Mr. Gonzalez before he was hired. The court stated that, as explained in its summary-judgment ruling, those complaints were the reason the negligent-hiring claim would proceed to trial.

The court granted in part and denied in part Motion No. 5 concerning future economic damages. The court granted the motion to the extent it barred Dr. Huckabee from testifying about the amount of future economic damages allegedly caused by the district’s negligence. The court gave three reasons: the plaintiffs had not disclosed that Dr. Huckabee would offer that opinion; she was not qualified to testify about at least some of the figures; and allowing the testimony would unfairly prejudice the district.

The court denied the motion to the extent it sought to bar Jane Doe from seeking future economic damages altogether. The court stated that, except for future earnings, the district had notice that she would seek future economic damages, and expert testimony was not necessarily required if she presented substantial supporting evidence. Because Jane Doe had disclaimed future earnings in discovery, the court ruled that lost future earnings could not be included. The order also stated that she had said she was not seeking lost income and therefore could not seek past or future lost income at trial.

Jane Doe’s Motions

The court granted in part and denied in part Jane Doe’s Motion in Limine No. 1 concerning evidence of her other sexual behavior. The court ruled that her prior sexual experience was not relevant to adequate supervision and that any marginal relevance would be outweighed by unfair prejudice. Evidence concerning other abusive sexual relationships might be relevant to damages, however. Before presenting such evidence, the district would have to make an offer of proof, meaning it would have to explain what the evidence would show and why it should be admitted.

The court denied Jane Doe’s Motion No. 2 as unnecessary because she had not identified any district exhibit that had not previously been disclosed during discovery.

The court denied Motion No. 3 as unnecessary because Jane Doe had not identified any person the district intended to call who had not been disclosed as an expert.

The court denied Motion No. 4 as overbroad. The court stated that lay witnesses might appropriately testify about their understanding of school-district policies and rules governing their actions involving Mr. Gonzalez’s hiring and supervision. Those witnesses could not testify about the legal meaning or effect of the rules and statutes, but Jane Doe’s counsel had not identified any specific expected testimony of that kind.

Disposition and Scope

The order denied the district’s Motions Nos. 1 through 4; granted in part and denied in part the district’s Motion No. 5; granted in part and denied in part Jane Doe’s Motion No. 1; and denied Jane Doe’s Motions Nos. 2 through 4. These were evidentiary rulings for trial, not a final decision on the underlying claims.