Haynes v. Acquino
692 F. App'x 670
| 2d Cir. | 2017Background
- Haynes was criminally prosecuted in Buffalo City Court; that court ruled her arrest lacked probable cause and suppressed evidence, a decision later reversed on appeal, but the City Court ultimately dismissed charges.
- Haynes sued Buffalo police officers and municipal entities under 42 U.S.C. § 1983 alleging false arrest and excessive force based on the same arrest.
- At a pretrial conference Haynes said she would offer the City Court’s written decision to show lack of probable cause; the district court ruled the City Court decision had no collateral estoppel effect and excluded its use to prove lack of probable cause, admitting a redacted version that removed the probable-cause finding.
- The case proceeded to trial; the jury found there was probable cause and returned a verdict for the defendants. The district court then granted the officers qualified immunity in part based on the jury’s findings.
- On appeal, this Court reviewed the district court’s evidentiary rulings and Rule 403 balancing, and examined whether excluding the unredacted City Court decision was harmless error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility/relevance of City Court decision on probable cause | Haynes: City Court decision is relevant to whether arrest lacked probable cause and should be admitted (even if not preclusive) | Defendants: City Court decision lacks collateral estoppel effect and is prejudicial; should be excluded | Court: Decision was relevant under Rule 401; district court erred to deem it irrelevant and to redact the probable-cause finding |
| Rule 403 balancing of probative value vs. prejudice | Haynes: Probative value outweighs any prejudice | Defendants: Admission would unfairly prejudice jury and confuse issues | Court: District court abused discretion by not adequately weighing probative value; reversed Rule 403 ruling |
| Harmlessness of evidentiary error | Haynes: Exclusion affected jury’s view of probable cause | Defendants: Jury likely would have reached same result; error harmless | Court: Error not harmless; cannot conclude exclusion did not substantially influence jury; verdict vacated |
| Qualified immunity relying on jury findings | Haynes: Qualified immunity should not be granted based on flawed jury findings | Defendants: Qualified immunity proper given jury answers | Court: Because jury findings may have been tainted by exclusion, qualified immunity ruling vacated and remanded |
Key Cases Cited
- United States v. Natal, 849 F.3d 530 (2d Cir.) (standard for reviewing evidentiary rulings)
- United States v. Mercado, 573 F.3d 138 (2d Cir.) (harmless-error test for erroneous evidentiary rulings)
- United States v. Certified Envtl. Servs., Inc., 753 F.3d 72 (2d Cir.) (broad scope of Rule 401 relevance)
- United States v. White, 692 F.3d 235 (2d Cir.) (‘‘relevant evidence is admissible’’ under Rule 402)
- Li v. Canarozzi, 142 F.3d 83 (2d Cir.) (trial judge’s broad discretion in Rule 403 balancing)
- United States v. Morgan, 786 F.3d 227 (2d Cir.) (reversal where probative value and prejudice not adequately considered)
- Dancy v. McGinley, 843 F.3d 93 (2d Cir.) (elements of false arrest and probable cause as a defense)
- Jenkins v. City of New York, 478 F.3d 76 (2d Cir.) (collateral estoppel limits in § 1983 cases)
- United States v. Litvak, 808 F.3d 160 (2d Cir.) (low threshold for relevance under Rule 401)