Mulford v. Union Pacific Railroad
321 P.3d 684
Idaho2014Background
- Mulford, a UP machinist, sued under FELA for knee injuries allegedly caused by UP’s negligence.
- Trial in May 2012; jury found UP not negligent; final judgment entered May 22, 2012.
- Mulford appeals alleging two trial errors: juror for-cause disqualification and admission of RRB benefits evidence for impeachment.
- Voir dire of a juror revealed the juror’s father worked for UP; juror stated no bias and could follow the court’s instructions.
- Mulford disputed the district court’s admission of evidence about Mulford receiving Railroad Retirement Board benefits to impeach his testimony.
- Mulford’s waiver argument: he did not renew a for-cause objection after the court rehabilitated the juror and he passed the panel for cause.
- District court allowed RRB-benefits impeachment evidence because Mulford opened the door with partial/misleading direct testimony; the court weighed probative value against prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Waiver of for-cause challenge to juror | Mulford argued for-cause bias should have led to disqualification | Mulford waived the objection by passing for cause without renewal | Mulford waived the issue; no reversible error on the for-cause disqualification |
| Admissibility of RRB benefits as impeachment evidence | Collateral source evidence should be inadmissible and not used for credibility | Court properly admitted to test Mulford’s credibility when he opened the door | District court did not abuse its discretion; RRB benefits admitted as impeachment evidence |
Key Cases Cited
- Morris ex rel. Morris v. Thomson, 130 Idaho 138, 937 P.2d 1212 (Idaho 1997) (abuse-of-discretion review for juror challenges)
- City of McCall v. Seubert, 142 Idaho 580, 130 P.3d 1118 (Idaho 2006) (evidence decisions reviewed for abuse of discretion)
- Van Brunt v. Stoddard, 136 Idaho 681, 39 P.3d 621 (Idaho 2001) (abuse-of-discretion standard in evidentiary rulings)
- Goodspeed v. Shippen, 154 Idaho 866, 303 P.3d 225 (Idaho 2013) (three-part test for abuse of discretion)
- Schmechel v. Dillé, 148 Idaho 176, 219 P.3d 1192 (Idaho 2009) (three-part abuse-of-discretion framework)
- State v. Bitz, 93 Idaho 239, 460 P.2d 374 (Idaho 1969) (juror-for-cause preservation and passing for cause)
- Hurtado v. Land O'Lakes, Inc., 153 Idaho 13, 278 P.3d 415 (Idaho 2012) (standards for appellate review of evidentiary rulings; substantial rights)
- Carroll v. MBNA America Bank, 148 Idaho 261, 220 P.3d 1080 (Idaho 2009) (costs on appeal are awarded as a matter of right; attorney fees require briefing)