Alley v. Long Island Railroad Company

Background

The Long Island Railroad Company filed a sealed motion in limine, which is a request to decide before trial whether particular evidence may be presented to the jury. The motion concerned evidence about a 2013 incident and resulting damage. The opinion identifies Alley's underlying claim as a negligence claim under the Federal Employers' Liability Act, based on an allegation that the railroad failed to clear a walkway after a snowstorm.

Arguments

The railroad argued that the 2013 incident and resulting damage should be excluded under Federal Rule of Evidence 401 because they were not causally related to the alleged negligence and therefore were not relevant. It also argued under Rule 403 that, even if the evidence had some relevance, its value was outweighed by the risk of unfair prejudice, jury confusion, and wasted time and court resources.

Alley argued that the evidence was relevant and that its value in showing the harm alleged in connection with her claims outweighed those concerns.

Ruling

Judge Lorna G. Schofield held that, as presented, the evidence could be relevant under Rule 401, but that its value was substantially outweighed by the danger of unfair prejudice under Rule 403. The court stated that allegations of egregiously wrongful workplace acts by the railroad's employee could unfairly prejudice the railroad and distract from Alley's negligence allegations.

The motion in limine was granted in part and denied in part. Alley may not present evidence about the nature of the 2013 incident or identify who was involved. She may present evidence, if otherwise admissible, that an incident occurred and how it contributed to her alleged injury in this case. At Alley's request, the court will provide an explanatory instruction to the jury. The Clerk of Court was directed to close the motion at Docket No. 30.