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Estate of Jeffrey Melvin v. City of Colorado Springs, Colorado
1:20-cv-00991
| D. Colo. | Mar 11, 2025
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Background

  • The Estate of Jeffrey Melvin brought a §1983 civil rights action against the City of Colorado Springs, alleging excessive force by police officers resulting in Melvin's death on April 26, 2018.
  • Individual officers were initially defendants, but the Tenth Circuit found they were entitled to qualified immunity, leaving only the City as defendant.
  • The case is proceeding to a 10-day jury trial set for August 2025.
  • The parties filed competing motions in limine seeking to exclude or admit various evidence, including Melvin's criminal history, drug use, medical records, and law enforcement policies.
  • The Court's ruling addresses which categories of evidence are admissible or excluded, shaping the scope and focus of the trial.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Admissibility of Melvin’s criminal history and arrest warrant Evidence is irrelevant and unfairly prejudicial, as officers were unaware of the warrant or charges; not relevant to excessive force inquiry Relevant to Melvin’s motive for resisting arrest and to damages Excluded; officers' lack of knowledge makes it irrelevant, and risk of prejudice outweighs probative value
Evidence of Melvin’s drug/alcohol use (other than cause of death) Should be excluded except as relates to cause of death Relevant to damages and possibly probative of circumstances Excluded except as related to cause of death; otherwise irrelevant and prejudicial
Use of term “homicide” and “killed” at trial Jury can understand medical use of “homicide”; should not be misleading Terms are inflammatory and may mislead jury "Homicide" limited to autopsy/death certificate and must be explained by experts; "killed" and "murder" excluded as prejudicial
Admission of late-disclosed cards, letters, and photos Disclosure is harmless Admission is prejudicial, as disclosure was too late after fact discovery Excluded; late disclosure not justified and prejudicial

Key Cases Cited

  • Graham v. Connor, 490 U.S. 386 (1989) (established the standard for evaluating excessive force claims under the Fourth Amendment)
  • United States v. Howell, 285 F.3d 1263 (10th Cir. 2002) (addresses Rule 609 and admissibility of criminal convictions for impeachment)
  • United States v. Jordan, 485 F.3d 1214 (10th Cir. 2007) (sets very low bar for admission under Rule 401)
  • United States v. Neal, 718 F.2d 1505 (10th Cir. 1983) (discretion of trial court in relevance and Rule 403 determinations)
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Case Details

Case Name: Estate of Jeffrey Melvin v. City of Colorado Springs, Colorado
Court Name: District Court, D. Colorado
Date Published: Mar 11, 2025
Docket Number: 1:20-cv-00991
Court Abbreviation: D. Colo.