Pruter v. Local 210's Pension Trust Fund

Background

The plaintiffs, former employees of World Airways, Inc., sued Local 210 under the Railway Labor Act, claiming that Local 210 breached its duty of fair representation by failing to fulfill a promise to fund part of the plaintiffs’ pensions. The case originally included claims under the Employment Retirement Income Security Act and state law, but the issues were later narrowed to the Railway Labor Act claim.

During fact discovery, the parties agreed that the plaintiffs’ counsel would select three plaintiffs whom Local 210 could depose. Their testimony would bind all plaintiffs concerning Local 210’s potential liability on the claims in the first amended complaint. The plaintiffs selected three, and Local 210 deposed them. The court had previously denied Local 210’s motion for summary judgment.

Motion in Limine

Local 210 filed a motion in limine, which is a request to control what evidence may be presented at trial. It asked the court to bar the plaintiffs from calling more plaintiffs as liability witnesses than the three already deposed.

The plaintiffs argued that the stipulation concerned discovery, not trial witnesses. They also argued that, even if the stipulation limited witnesses concerning events in 1996, it did not prevent them from calling additional plaintiffs to testify about events after 1996.

Court’s Analysis

The court interpreted the stipulation to prohibit the plaintiffs from calling more than the three deposed plaintiffs as witnesses on liability at trial. The court reasoned that discovery is intended to identify the evidence available for trial and to prevent surprise. Limiting the parties’ ability to gather evidence during discovery, but allowing additional evidence at trial, would undermine that purpose.

The court also concluded that the stipulation covered the entirety of potential liability arising from the claims in the first amended complaint, not just events occurring in 1996. Therefore, the plaintiffs could not call additional plaintiffs to testify about liability based on events after 1996.

The court expressly did not decide whether events after 1996 could create liability. It also did not address the proper measure of damages or whether additional plaintiffs could testify about damages.

Disposition

Judge Analisa Torres granted Local 210’s motion in limine. At trial, on the issue of liability, including events after 1996, the plaintiffs were barred from calling more plaintiffs as witnesses than the three already deposed. The Clerk of Court was directed to terminate the motion.