L.C. v. State of California
5:22-cv-00949
C.D. Cal.Apr 17, 2025Background
- The case arises from the shooting death of Hector Puga following a high-speed police pursuit and standoff.
- Plaintiffs, including Puga's mother and three minor children, brought claims against various State and County defendants, alleging wrongdoing in the use of force that led to Puga’s death.
- A key evidentiary dispute concerns a black-and-white surveillance video purportedly taken by a neighbor, "Sal," which Plaintiffs now seek to introduce at trial.
- Defendants argue the video is unauthenticated, unreliable, and potentially prejudicial, as its origin and accuracy cannot be established since "Sal" did not appear for deposition.
- Plaintiffs previously indicated they would not use this video but reversed their position shortly before trial, prompting Defendants to bring this motion in limine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of "Sal's" unauthenticated video | Video relevant to witness Botten's trauma after viewing it | Video lacks authentication, foundation, and is prejudicial | TBD |
| Relevance under Federal Rules of Evidence 401/402 | Video’s effect on witness trauma is contextually relevant | Video not factually related to Puga case; irrelevant to claims | TBD |
| Prejudice vs. Probative Value under Rule 403 | Any prejudicial effect outweighed by insight into trauma | Minimal probative value substantially outweighed by prejudice | TBD |
| Use of alternative (authenticated) evidence | Video uniquely relevant to Botten’s emotional experience | Other, better, authenticated videos available | TBD |
Key Cases Cited
- Luce v. United States, 469 U.S. 38 (motions in limine may be used to exclude prejudicial evidence before trial)
- U.S. v. Young, 754 F. Supp. 739 (prejudice under Rule 403 requires evidence to create a risk of emotionally-based decisions)
- U.S. v. Guerrero, 756 F.2d 1342 (evidence not closely related to an issue and irrelevant may be substantially outweighed by unfair prejudice)
- U.S. v. Blaylock, 20 F.3d 1458 (discussing the balancing test under Rule 403)
- Brodit v. Cambra, 350 F.3d 985 (motions in limine help avoid exposure of jurors to inadmissible evidence)
- United States v. Tokash, 282 F.3d 962 (motions in limine serve to reduce trial disruptions by resolving evidentiary disputes in advance)