Castillo v. Progressive Insurance, 3:19-cv-01628

On June 12, 2015, Irma Castillo was a passenger in a vehicle involved in a crash with an uninsured motorist; she alleges head, neck, and back injuries.
At the time, the vehicle was insured by GEICO; Castillo also had UM/UIM coverage under Allstate ($15,000, stacking for two vehicles) and Progressive ($15,000 per vehicle, stacking for three vehicles for a total of $45,000).
GEICO settled with Castillo for its $15,000 policy limits on May 10, 2019.
Castillo sued Progressive for uninsured/underinsured motorist benefits; her bad-faith claim was previously dismissed, leaving only the contract/UIM damages claim.
Progressive moved in limine to exclude any evidence or references to its policy limits and to premiums Castillo paid for the Progressive policy as irrelevant and prejudicial.
The court granted the motion, excluding policy limits and premium information from trial as irrelevant and unduly prejudicial/likely to confuse the jury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Relevance of policy limits and premium payments under Rules 401/402	Policy limits/premiums are relevant to the UIM recovery assessment	Policy limits/premiums do not tend to make any fact about Castillo’s injuries more or less probable; undisputed facts not for jury	Excluded: court found limits/premiums not relevant to jury’s determination of injuries/damages
Rule 403 prejudice/confusion	Any probative value outweighs risk of prejudice	Evidence would unfairly prejudice/anchor jurors, confuse issues, and distract from injury assessment	Excluded: probative value substantially outweighed by danger of unfair prejudice and jury confusion

Luce v. United States, 469 U.S. 38 (1984) (district courts may rule on motions in limine).
In re Japanese Elec. Prods. Antitrust Litig., 723 F.2d 238 (3d Cir. 1983) (district courts exercise discretion to rule in limine).
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (cited regarding appellate treatment of related rulings).
United States v. Romano, 849 F.2d 812 (3d Cir. 1988) (exclusion of evidence to prevent unfair prejudice/confusion).
Bradley v. Pittsburgh Bd. of Educ., 913 F.2d 1064 (3d Cir. 1990) (in limine rulings help narrow evidentiary issues).
Abrams v. Lightolier Inc., 50 F.3d 1204 (3d Cir. 1995) (Rule 403 balancing reviewed for abuse of discretion).
Bernardsville Bd. of Educ. v. J.H., 42 F.3d 149 (3d Cir. 1994) (review standard for in limine evidentiary rulings).
Spain v. Gallegos, 26 F.3d 439 (3d Cir. 1994) (explicating Rule 401’s low bar for relevance).
United States v. Sriyuth, 98 F.3d 739 (3d Cir. 1996) (Rule 402 presumption that relevant evidence is admissible).
Frank v. County of Hudson, 924 F. Supp. 620 (D.N.J. 1996) (discussion of breadth of Rule 401 relevance).