Minter v. City of San Pablo, 3:12-cv-02905

This is a 42 U.S.C. § 1983 civil rights case in the N.D. Cal. involving Officer Galios’ use of deadly force against decedent Akinlabi Minter.
Plaintiffs seek damages for Fourth and Fourteenth Amendment claims and loss of familial relations with Minter.
Defendant moved to limit evidence via motions in limine; Plaintiffs moved to amend the complaint.
Court granted leave to amend to add a Fourteenth Amendment claim but struck non- Fourteenth Amendment enhancements from the proposed amendments.
Court granted bifurcation of liability and punitive damages; set schedule for pretrial conference and jury trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plaintiffs may amend to add a Fourteenth Amendment claim and damages.	Plaintiffs seek recovery for loss of familial relations and a Fourteenth Amendment claim.	Amendment would prejudice Galios and cause undue delay; damages limited under current claims.	GRANTED to add Fourteenth Amendment claim; however, non-declaratory amendments are STRICKEN.
Whether the amendment would be prejudicial, futile, or unduly delayed.	Amendment is proper under Rule 15; no undue prejudice.	Amendment would prejudice, be futile, or cause delay.	No substantial prejudice or futility; amendment allowed within scope stated.
Whether expert testimony and other in limine evidence should be limited or excluded.	Certain expert opinions are admissible to contextualize the incident.	Some expert opinions are improper ultimate-issue opinions or irrelevant.	Partial exclusion and qualification of expert testimony; some opinions admitted with limits; others excluded.
Whether evidence of Minter’s parole status and criminal history is admissible.	Parole status and history bear on motive and damages; probative value outweighs prejudice.	Some evidence prejudicial or irrelevant; limits apply.	Parole status admitted for motive/damages; prior prison terms limited; other details excluded.
Whether to bifurcate liability and punitive damages.	N/A in this summary.	Bifurcation would avoid prejudice from financial-conditions evidence.	GRANTED unopposed; trials will be bifurcated.

AmerisourceBergen Corp. v. Dialysist West, Inc., 465 F.3d 946 (9th Cir. 2006) (liberal amendment standard under Rule 15; prejudice analysis weighs heavily)
Owens v. Kaiser Foundation Health Plan, Inc., 244 F.3d 708 (9th Cir. 2001) (undue delay and prejudice as central to amendment rulings)
Zenith Radio Corp. v. Hazeltine Research, Inc., 401 U.S. 321 (1971) (prejudice is the most important factor in amendments)
Billington v. Smith, 292 F.3d 1177 (9th Cir. 2002) (demonstrates that negligent actions may not preclude reasonable force as a matter of law)
Porter v. Osborn, 546 F.3d 1131 (9th Cir. 2008) (purpose-to-harm standard for Fourteenth Amendment familial rights)
Boyd v. City and County of San Francisco, 576 F.3d 938 (9th Cir. 2009) (relevance of pre-incident statements to credibility and incident)
In re Cornfield, 365 F. Supp. 2d 271 (E.D.N.Y. 2005) (privity-based admissions not adopted under Rule 801(d)(2))