Jones v. Mora
- Thomas Hixson
- 3:20-cv-04093
- U.S. District Court · Northern District of California
- 11
In Jones v. Mora, Judge Hixson ruled on trial-evidence motions, excluding or limiting several categories and requiring Amos Jones’s legs to be shackled.
Amos Jones and the defendants in the upcoming trial; the order also directs what the jury may hear and how Jones will appear and move during trial.
What happened
In Jones v. Mora, the court addressed both sides’ requests to control what evidence the jury could hear at trial. The case involves Amos Jones’s claims concerning an alleged sexual assault, excessive force, and retaliation.
The court granted all four of the defendants’ motions. It excluded evidence of other inmates’ grievances and lawsuits, excluded a witness’s proposed statement about what Jones said after the alleged assault unless Jones first establishes the required foundation, separated any punitive-damages phase from the liability and compensatory-damages phase, and excluded evidence that California might pay or reimburse a judgment. The court granted Jones’s first motion and excluded his prior convictions. It granted in part and denied in part his second motion, excluding evidence of his prison conduct and alleged gang affiliation subject to possible rebuttal or impeachment if he opens the door. It granted his third motion, excluding prior complaints subject to possible rebuttal, and denied his fourth motion seeking to attend trial without shackles.
Judge Thomas S. Hixson ordered that Jones’s legs be shackled during trial, while directing that tables be covered so the jury would not see the shackles and allowing Jones to wear civilian clothes. The jury will also be excused when Jones must move around the courtroom.
The detailed version
- Jones v. Mora · No. 3:20-cv-04093
- Thomas Hixson
- Dec. 1, 2022
Background
The court held a pretrial conference on December 1, 2022, and heard oral argument on the parties’ motions in limine, which are pretrial requests to decide whether particular evidence may be presented to the jury. Jones’s claims concern an alleged sexual assault during a clothed body search, excessive force, and retaliation for filing a prison grievance. The order addresses what evidence may be used at the upcoming trial and how the trial will be conducted.
Defendants’ Motions
The court granted Defendants’ Motions in Limine Nos. 1–4.
1. Other inmates’ grievances and lawsuits. The court granted Motion No. 1 and excluded evidence of grievances and lawsuits by other inmates against the defendants. It found that those matters had little value because they did not involve the facts of Jones’s case and could unfairly prejudice or confuse the jury.
2. Witness testimony about Jones’s statement. The defendants sought to prevent Jason Smith from testifying that Jones told him, “I had just been assaulted.” Jones argued that the statement was admissible under exceptions to the hearsay rule for statements made during or immediately after a startling event. The court found the evidence offered by Jones insufficient to show that the required conditions for those exceptions were met. The statement therefore could not be admitted on the record presented. The court stated that Jones could raise the issue during trial, outside the jury’s presence, if he established the required foundation.
3. Separate punitive-damages phase. The court granted Motion No. 3 and ordered the trial divided into a liability and compensatory-damages phase and, if the jury found Jones entitled to punitive damages, a separate phase to determine the amount of punitive damages. The same jury would decide the later amount if that phase became necessary.
4. California indemnification. The court granted Motion No. 4 and excluded evidence that the State of California would pay or reimburse the defendants for a verdict or compensatory-damages award.
Jones’s Motions
1. Prior convictions. The court granted Jones’s Motion in Limine No. 1. Neither side may introduce evidence of Jones’s prior convictions. The court found that their prejudicial effect substantially outweighed their value in this civil case.
2. Prison conduct and alleged gang affiliation. The court granted in part and denied in part Jones’s Motion in Limine No. 2.
- The court granted the motion regarding Jones’s prison conduct before November 23, 2019. The defendants may not introduce that conduct or related disciplinary evidence, although they may use rebuttal evidence if Jones claims he is a “model inmate.” - The court granted the motion regarding conduct after November 23, 2019, including Jones’s placement in administrative segregation. The court found that Jones’s trial filings had narrowed his retaliation theory to the alleged sexual assault, making the administrative-segregation evidence irrelevant to the issues remaining for trial. - Regarding alleged gang affiliation, the court granted the motion in part and denied it in part. The alleged gang-affiliation evidence is excluded, but it may become admissible for impeachment or rebuttal if Jones opens the door to that subject.
3. Prior prison complaints. The court granted Jones’s Motion in Limine No. 3 and excluded evidence of his prior complaints. If Jones testifies about his history of filing grievances, however, the defendants may introduce rebuttal evidence concerning those prior complaints.
4. Shackles. The court denied Jones’s Motion in Limine No. 4, which sought to allow him to attend trial without shackles. After considering his violent criminal history, the information provided about his security scores, the incomplete disciplinary record, and the length of his sentence, the court found a compelling need for limited shackling. Jones’s legs must be shackled during trial. To reduce possible prejudice, the court ordered that counsel tables be covered so the jury cannot see the shackles and that the jury be excused when Jones moves into, around, or out of the courtroom. The court also ordered that Jones be allowed to wear civilian clothes, with his counsel responsible for providing them to the United States Marshals each morning.
Read the full 11-page opinion on CourtListener, the free public archive maintained by the Free Law Project.