Williams v. Aaron Johnson

Background

The trial scheduling order required the parties to file any motions in limine—pretrial requests asking the court to limit or exclude evidence—by November 20, 2020. On that date, defendant Aaron Johnson filed a motion seeking two forms of relief:

1. dismissal of Jamal Williams’s malicious-prosecution and denial-of-the-right-to-a-fair-trial claims because, according to Johnson, Williams could not establish that the criminal case against him ended favorably; and 2. an order preventing Williams from asking about Johnson’s disciplinary history or civil-rights lawsuits.

After obtaining and reviewing the transcript of the state-court proceeding where the criminal case was dismissed, Johnson withdrew the portion of his motion seeking dismissal of those two claims. The transcript stated that the prosecution moved to dismiss because it could not prove beyond a reasonable doubt that the defendant exercised control over the firearm and marijuana recovered during execution of the search warrant.

Parties’ Positions

In his opposition, Williams stated that he did not intend to introduce evidence of allegations that Johnson engaged in other misconduct, or evidence from complaints or investigations by the Civilian Complaint Review Board or the Internal Affairs Bureau. Williams also said he would not present the fact or substance of other civil lawsuits.

Williams stated that he would seek to prevent Johnson from introducing evidence of Williams’s criminal history, if any, under the federal rules governing relevance and unfair prejudice. Williams also argued that Johnson and other police witnesses should not be allowed to introduce commendations, promotions, or other evidence portraying their professional achievements and good citizenship, because doing so could open the door to evidence of prior wrongdoing.

Rulings

The court granted the remaining portion of Johnson’s motion because Williams did not oppose it. Williams was precluded at trial from asking about any disciplinary history or civil-rights actions filed against Johnson.

To the extent Williams’s opposition was intended to be a cross-motion seeking an order concerning his criminal history or evidence about the prior professional achievements and good citizenship of Johnson or other police witnesses, the court denied that motion as untimely. The court also observed that the parties had elected a bench trial, meaning the judge rather than a jury would decide the case, and that there was therefore virtually no potential for undue prejudice.