Jolibois v. Public Health Trust of Miami-Dade County Florida
1:23-cv-24442
S.D. Fla.Apr 14, 2025Background
- Plaintiff Marie Jolibois sued the Public Health Trust of Miami-Dade County (PHT) alleging multiple counts of workplace discrimination, retaliation, and FMLA violations.
- The case was removed to federal court based on federal question and supplemental jurisdiction.
- On March 31, 2025, the Court granted summary judgment to PHT on all claims except Count XIII (FMLA interference), which is set for trial.
- Both parties filed motions in limine seeking to exclude certain categories of evidence from trial.
- The Court ruled on these motions ahead of the trial scheduled for April 21, 2025.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclusion of settlement offers | Such references should not be allowed. | No objection if within Federal Rules. | Granted |
| Exclusion of prior/other lawsuits | Requests exclusion; claims such evidence is irrelevant. | Objects as too vague. | Denied |
| Exclusion of undisclosed witnesses/experts | Seeks to exclude non-disclosed witnesses. | Argues motion is too vague. | Denied |
| Exclusion of character attacks/name calling | Seeks to exclude prejudicial character attacks. | No objection. | Granted |
| Exclusion of collateral source benefits | Wants to exclude mention of benefits (e.g., unemployment, SSDI). | Motion is vague. | Denied |
| Exclusion of time-off/medical leave abuse inferences | Time-off use protected; seeks to preclude negative inferences of abuse. | Motion is vague; relevance depends on evidence specifics. | Denied |
| Exclusion of disability appearance arguments | Exclude claims plaintiff is not disabled because she looks "fine." | No objection per federal rules. | Granted |
| Exclusion of lay opinions on fitness | Exclude non-expert opinions implying unfitness/mental health issues. | No objection per federal rules. | Granted (to extent Rule 701 applies) |
| Exclusion of unrelated employment history | Exclude work history outside defendant employer as irrelevant. | No objection per federal rules. | Granted |
| Exclusion of damages-related evidence | Exclude evidence about defendant's hardship/emotional harm. | No response. | Granted |
| Exclusion of evidence for dismissed claims | No objection to excluding discrimination/retaliation claims but resignation relevant for damages. | Seeks to exclude all evidence of dismissed claims and constructive discharge. | Granted, except resignation evidence not allowed for damages |
| Exclusion of unrelated matters to eye surgeries | FMLA use/leave requests after surgeries relevant to damages. | Wants to preclude unrelated matters; cites Rule 403. | Denied (decision deferred for trial) |
Key Cases Cited
- United States v. Gonzalez, 718 F. Supp. 2d 1341 (S.D. Fla. 2010) (standard for motions in limine; exclude only when clearly inadmissible)
- United States v. Patrick, 513 F. App’x 882 (11th Cir. 2013) (evidence is relevant if it makes any fact more or less probable)
- United States v. Lopez, 649 F.3d 1222 (11th Cir. 2011) (Rule 403 balancing should favor admissibility)
- United States v. Grant, 256 F.3d 1146 (11th Cir. 2001) (Rule 403’s main function is to exclude evidence with minimal probative force dragged in for prejudicial effect)