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Huddleston v. Pohlman

February 27, 2007

RANDY HUDDLESTON, PLAINTIFF,
v.
PHILLIP D. POHLMAN, DEFENDANT.



The opinion of the court was delivered by: Jeanne E. Scott, U.S. District Judge

OPINION

This matter is before the Court on Defendant's Motion to Bifurcate Trial into a Liability Phase and a Damages Phase (d/e 18) and Motion in Limine (d/e 19). As set forth below, the Motion to Bifurcate is allowed, and the Motion in Limine is allowed, in part, and denied, in part.

A. MOTION TO BIFURCATE

Defendant asks the Court to bifurcate the trial into a liability phase and a damages phase. See Fed. R. Civ. P. 42(b). This "[C]court may bifurcate a trial provided that this ruling 1) serves the interests of judicial economy or is done to prevent prejudice to a party; 2) does not unfairly prejudice the non-moving party; and 3) does not violate the Seventh Amendment." Krocka v. City of Chicago, 203 F.3d 507, 516 (7th Cir. 2000). Defendant asserts that bifurcation would promote judicial economy and avoid prejudice to the Defendant. Plaintiff contends that bifurcation would increase the overall length of the trial and that any prejudice to the Defendant could be avoided with the use of limiting instructions.

The parties agree that the trial, as a whole, will be relatively brief. Therefore, bifurcation would at best only slightly further the interest of judicial economy. However, as Defendant points out, Plaintiff indicates that he wishes to introduce evidence regarding Defendant's subjective intentions in arresting him. Defendant's state of mind, while relevant to the question of punitive damages, is irrelevant to the question of liability. Allowing the jury to hear evidence relating to Defendant's subjective intent at the liability stage could prejudice Defendant. Similarly, Plaintiff seeks to introduce evidence of his acquittal on the underlying criminal charges in connection with his request for damages arising out of his bond restrictions. Again, this potentially prejudicial evidence is not relevant to the question of liability, only to the question of damages. Furthermore, Plaintiff does not identify any prejudice he would suffer if the matter were bifurcated. Weighing all of the relevant factors, the Court believes that bifurcation is appropriate. Defendant's Motion to Bifurcate is, therefore, allowed. The trial will be bifurcated into a liability phase and a damages phase. If Plaintiff prevails at the liability stage, the damages phase will begin at 9:00 a.m. the following day.

B. MOTION IN LIMINE

Defendant seeks to bar Plaintiff from introducing evidence that falls into six distinct categories, set forth below. Under the Federal Rules of Evidence, in order for evidence to be admissible, it must be relevant. Fed. R. Evid. 402. Relevant evidence is defined as: "evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence." Fed. R. Evid. 401. "Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence." Fed. R. Evid. 403.

1. Damages of Timberline Enterprises

Defendant seeks to bar any evidence or argument relating to damages allegedly incurred by Timberline Enterprises as a result of Plaintiff's arrest.

Timberline Enterprises is a trucking corporation owned by Plaintiff's wife, Annette Huddleston. Plaintiff was the Secretary/Treasurer of Timberline Enterprises. Plaintiff was also a salaried employee of the corporation, working as an over-the-road truck driver. Plaintiff submits that his damage testimony will be that, subsequent to his arrest, he was placed under a bond restriction. As a condition of the bond, Plaintiff was not permitted to leave the state of Illinois from the time of his arrest until his acquittal. Plaintiff maintains that he spoke with the State's Attorney about having this travel restriction lifted, and the State's Attorney indicated an unwillingness to do so. Plaintiff never petitioned the Court to lift the restriction. As a result of the travel restriction, Plaintiff maintains that he was unable to drive approximately 80% of the routes that he normally did for Timberline. Plaintiff asserts that Timberline was forced to sell off equipment and eventually cease operations.

Neither Timberline Enterprises nor its sole shareholder, Annette Huddleston, are parties to the instant lawsuit. Plaintiff cites no authority to support his position that he has standing to recover damages to Timberline, which he characterizes as "a family owned business." Plaintiff's Memorandum of Law in Opposition to Defendant's Motion in Limine (d/e 21) (Plaintiff's Memorandum), p. 3. Moreover, even if Plaintiff were a shareholder of Timberline, "a plaintiff-shareholder cannot maintain a civil rights action for damages suffered by the corporation." Flynn v. Merrick, 881 F.2d 446, 450 (7th Cir. 1989). Therefore, the evidence relating to damages allegedly incurred by Timberline Enterprises as a result of Plaintiff's arrest is not relevant. Defendant's request to bar such evidence and argument relating to it is allowed.

2. Damages to Plaintiff Because of Bond Restrictions

Defendant seeks to bar any evidence or argument relating to damages allegedly incurred by Plaintiff because of the bond restriction prohibiting him from traveling out of state. A § 1983 claim creates tort liability; thus, the damages available to Plaintiff are governed by the principles of tort law. Memphis Comm. Sch. Dist. v. Stachura, 477 U.S. 299, 305-06 (1986). "Ordinarily, to obtain an award of compensatory monetary damages under § 1983, a plaintiff must demonstrate both that he has suffered an 'actual' present injury and that there is a causal connection between that injury and the deprivation of a constitutionally protected right caused by a defendant." Henderson v. Sheahan, 196 F.3d 839, 848 (7th Cir. 1999). Defendant asserts that the State's Attorney's decision to charge Plaintiff and Plaintiff's failure to petition the Court to remove the travel restrictions were intervening events that proximately caused any damages relating to Plaintiff's inability to leave the state, breaking any causal link to Defendant's conduct.

Under Illinois law, proximate cause is generally a question for the trier of fact. First Springfield Bank & Trust v. Galman, 720 N.E.2d 1068, 1071 (Ill. 1999). Whether a defendant's acts are the proximate cause of an injury depends upon whether the injury was of a type that a reasonable person would see as a likely result of his conduct. Id. Turning to the instant case, a reasonable jury could find that it was reasonably foreseeable to Defendant that his arrest of Plaintiff would likely result in criminal charges being filed and Plaintiff being placed on bond restrictions. Therefore, the Court will not bar ...


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