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Hamilton v. County of Madison

United States District Court, S.D. Illinois

February 10, 2015

REGINALD PITTMAN, By and through his Guardian and Next Friend, Robin M. Hamilton, Plaintiff,
v.
COUNTY OF MADISON, STATE OF ILLINOIS, et al., Defendants.

MEMORANDUM AND ORDER

STACI M. YANDLE, District Judge.

This matter comes before the Court on Defendants' Motion in Limine (Doc. 159). The Court heard argument on the Motion on February 4, 2015. For the following reasons, the Court grants in part and denies in part the motion.

At the hearing, Plaintiff indicated he had no objection to Motions in Limine Numbers 5 through 15. As such, the Court grants Defendants' Motions in Limine Numbers 5-15. With respect to Motion in Limine Number 5, the Court grants the Motion only with respect to the adequacy of the Madison County Jail's policies and procedures. Accordingly, the Court ORDERS that Plaintiff shall not argue or produce evidence regarding the following subjects: adequacy of Madison County Jail's policies and procedures (MIL 5); liability of any of the dismissed Defendants (MIL 6); any application for insurance, insurance policy, or statement or testimony concerning whether Defendants may have insurance in connection with Plaintiff's claim (MIL 7); any indication of the size of the law firm representing Defendants (MIL 8); any reference to settlement negotiations or the lack thereof (MIL 9); the current or former financial status or size of Defendants (MIL 10); any reference to allegations, investigations, claims, lawsuits status of lawsuits, or other matters asserted against any Defendant (MIL 11); any reference to any statements or photographs not previously provided to defendants' attorney and any testimony by a witness or expert witness not previously identified (MIL 12); any testimony or documents pertaining to the personal lives of Defendants (MIL 13); any references to Plaintiff as a "victim" or "victimized" (MIL 14); and the fact that Defendants filed this motion in limine or any other motions in limine (MIL 15).

MIL Number One

Defendants' Motion in Limine Number One seeks to exclude evidence regarding Plaintiff's previous medical care at the Madison County Jail, his high school records, and any other evidence prior to his detention at the Madison County Jail because they are irrelevant, unfairly prejudicial, confuse the issues, and waste time.

The Court finds that any evidence relating to Plaintiff's previous medical care at the Madison County Jail, his high school records, or other evidence prior to his detention at Madison County jail are not relevant to any remaining facts to be found by the jury. As such, the Court grants Motion in Limine Number One.

MIL Number Two

Defendants' Motion in Limine Number Two seeks to exclude evidence of prior suicides and suicide attempts at the Madison County Jail. Defendants argue that "the fact that other inmates attempted suicide does not demonstrate that the jail policies were inadequate or that officials were aware of any suicide risk posed by the policies or that officials failed to take appropriate steps to protect Plaintiff" (Doc. 159).

The Supreme Court has explained that:

[w]hether a prison official had the requisite knowledge of a substantial risk is a question of fact subject to demonstration in the usual ways, including inference from circumstantial evidence, cf. Hall 118 (cautioning against "confusing a mental state with the proof of its existence"), and a factfinder may conclude that a prison official knew of a substantial risk from the very fact that the risk was obvious. Cf. LaFave & Scott ยง 3.7, p. 335 ("[I]f the risk is obvious, so that a reasonable man would realize it, we might well infer that [the defendant] did in fact realize it; but the inference cannot be conclusive, for we know that people are not always conscious of what reasonable people would be conscious of"). For example, if an Eighth Amendment plaintiff presents evidence showing that a substantial risk of inmate attacks was "longstanding, pervasive, well-documented, or expressly noted by prison officials in the past, and the circumstances suggest that the defendant-official being sued had been exposed to information concerning the risk and thus must have known' about it, then such evidence could be sufficient to permit a trier of fact to find that the defendant-official had actual knowledge of the risk."

Farmer v. Brennan, 511 U.S. 825, 842-43 (1994).

Here, as the Court indicated in Farmer v. Brennan , the previous suicides would serve as evidence showing that the risk of suicide by detainees at the jail was "longstanding, pervasive, well-documented, or expressly noted by prison officials in the past." The evidence would further suggest that the Defendants "had been exposed to information concerning the risk and thus must have known." This evidence would thus permit the jury to conclude that Defendants had actual knowledge of the risk of suicide to Plaintiff and it is relevant. However, the Court believes that the potential prejudice associate with this evidence outweighs its probative value. Even with careful instruction, jurors may conclude that Defendants are liable because they "should have known" about the risk of suicide to Plaintiff rather than determining that Defendants were actually aware that Plaintiff was suicidal. As such, the Court grants Motion in Limine Number Two.

MIL Number Three

Defendants' Motion in Limine Number Three seeks to exclude letters written by Plaintiff. Plaintiff seeks to introduce a letter, characterized as a "suicide note, " written by Plaintiff to family members and retrieved after Plaintiff's suicide attempt. Defendants argue the letter is inadmissible because it does not indicate Defendants' subject knowledge of ...


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