797 F.Supp.3d 1243
N.D. Okla.2025Background
- Malcolm Scott and De’Marchoe Carpenter, having been exonerated after decades of imprisonment, filed suit under 42 U.S.C. § 1983 and state law against the City of Tulsa and certain police officers.
- The plaintiffs allege constitutional violations related to their wrongful convictions, including Brady violations, fabrication of evidence, and municipal liability for failure to train.
- After discovery, the Court granted in part and denied in part defendants’ motion for summary judgment; several key claims proceeded toward trial.
- The parties filed numerous motions in limine regarding the admissibility of various types of evidence in the forthcoming trial.
- The Court addressed these pretrial evidentiary disputes, granting, denying, or deferring rulings as appropriate, often deferring until trial context could be properly evaluated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of State’s declaration of actual innocence | Relevant to liability, damages, and fairness; exclusion would be unfairly prejudicial | Not relevant to surviving claims; highly prejudicial | Denied; may consider stipulation or limiting instruction |
| Evidence of alleged gang affiliation | Irrelevant, highly prejudicial, inadmissible character evidence | Relevant to witness motivations and defense to alleged coercion/fabrication | Denied without prejudice; will consider at trial |
| Prior bad acts/character evidence | Should be barred as inadmissible character evidence | May be required depending on trial presentation, relevant for other permissible purposes | Denied without prejudice; context-dependent |
| Affidavits of Price, Williams, Benson (hearsay) | Admissible under hearsay exceptions (e.g., statements against penal interest), or nonhearsay purposes | Constitutes inadmissible hearsay; no exceptions apply | Denied without prejudice; trial context will control |
Key Cases Cited
- Edens v. The Netherlands Ins. Co., 834 F.3d 1116 (10th Cir. 2016) (Defines the purpose and court’s discretion regarding motions in limine)
- Cardinas Garcia v. United States, 596 F.3d 788 (10th Cir. 2010) (Outlines factors for admissibility of 404(b) evidence)
- Hampton v. Dillard Dep’t. Stores, Inc., 247 F.3d 1091 (10th Cir. 2001) (Discusses remoteness and probative value for impeachment evidence)
- United States v. Page, 808 F.2d 723 (10th Cir. 1987) (Lists acts admissible for impeachment under Rule 608(b))
- Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993) (Liberal relevancy standard under the Federal Rules of Evidence)