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