United States District Court, E.D. Michigan, Southern Division
INTERNATIONAL UNION, UNITED AUTOMOBILE, AEROSPACE, AND AGRICULTURAL IMPLEMENT WORKERS OF AMERICA UAW, AND ITS LOCAL 1869, Plaintiffs,
GENERAL MOTORS, LLC, Defendant.
ORDER DENYING PLAINTIFFS' MOTION IN LIMINE
(DOCUMENT NO. 82) AND DENYING IN PART AND GRANTING IN PART
DEFENDANT'S MOTION IN LIMINE (DOCUMENT NO. 83)
HONORABLE STEPHEN J. MURPHY, III, JUDGE.
UAW and its Local 1869 filed a complaint alleging that
Defendant General Motors violated a Collective Bargaining
Agreement. Compl., ECF No. 1. According to the complaint, GM
breached seniority provisions of the Agreement by discharging
three employees and then refusing to recall them at a later
date. Id. Both parties have filed motions in limine
in advance of trial. See Mots., ECF Nos. 82, 83. For
the reasons stated below, the Court will deny UAW's
motion and will grant in part and deny in part GM's
Bosman, Linda Chapman, and Ovidiu Kowalski worked for GM in
the Surface Product Engineering (SPE) unit. Mot., ECF No. 82.
In September 2009, GM ended the employment of the Plaintiffs.
Id. From April 2010 to December 2010, GM hired new
employees into the SPE unit. Id. UAW asserts that GM
violated the Agreement by terminating Bosman, Chapman, and
Kowalski since they were senior to other employees in the SPE
unit. Id. UAW also alleges that GM's failure to
recall Bosman, Chapman, and Kowalski during re-hiring
violated the Agreement. Id. In preparation for
upcoming trial of the factual issues in the case, each party
has filed a motion in limine asking the Court to exclude
certain categories of evidence.
the Federal Rules of Evidence do not explicitly authorize
in limine rulings, the practice has developed
pursuant to the district court's inherent authority to
manage the course of trials." Luce v. United
States, 469 U.S. 38, 41 n.4 (1984). "A ruling on a
motion in limine is no more than a preliminary, or advisory,
opinion that falls entirely within the discretion of the
district court." United States v. Yannott, 42
F.3d 999, 1007 (6th Cir. 1994). Motions in limine may promote
"evenhanded and expeditious management of trials by
excluding evidence that is clearly inadmissible for any
purpose." Indiana Ins. v. Gen. Elec. Co., 326
F.Supp.2d 844, 846 (N.D. Ohio 2004). A court, however, should
"rarely" grant motions in limine that "exclude
broad categories of evidence." Sperberg v. Goodyear
Tire & Rubber Co., 519 F.2d 708, 712 (6th Cir.
1975). The "better practice is to deal with questions of
admissibility of evidence as they arise." Id.
Federal Rules of Evidence provide that "[r]elevant
evidence is admissible." Fed.R.Evid. 402. Relevant
evidence is defined as evidence having "any tendency to
make a fact more or less probable than it would be without
the evidence." Fed.R.Evid. 401. The rule erects a
"low bar" for the offering party to overcome.
United States v. Mackey, 249 F.App'x 420, 426
(6th Cir. 2008). Rulings on the relevance of evidence are
entrusted to the discretion of the trial judge. Morales
v. Am. Honda Motor Co., 151 F.3d 500, 516 (6th Cir.
1998) (quotations omitted).
Rules also provide for the exclusion of relevant evidence
"if its probative value is substantially outweighed by a
danger of one or more of the following: unfair prejudice,
confusing the issues, misleading the jury, undue delay,
wasting time, or needlessly presenting cumulative
evidence." Fed.R.Evid. 403. The Court has "broad
discretion in balancing probative value against potential
prejudicial impact." United States v. Feinman,
930 F.2d 495, 499 (6th Cir. 1991). In addition, the Court
"must look at the evidence in the light most favorable
to its proponent, maximizing its probative value and
minimizing its prejudicial effect." Sutkiewicz v.
Monroe Cnty. Sheriff, 110 F.3d 352, 360 (6th Cir. 1997)
UAW's Motion in Limine
argues that the Court should bar admission of evidence
related to GM's 2009 bankruptcy, and information related
to work performed in the SPE unit after January 2011. Mot.,
ECF No. 82.
GM's 2009 Bankruptcy
contends that information regarding the facts and events
surrounding GM's 2009 bankruptcy have no relevance to the
questions of fact that will be presented to the jury.
Id. at 2. Additionally, UAW submits that admission
of information related to GM's finances in 2009 would
incite the jury's emotions and constitute unfair
prejudice. Id. at 4.
Court disagrees. Relevance is a "low bar" and the
state of GM's finances when it terminated Bosman,
Chapman, and Kowalski clears the hurdle. Specifically,
GM's bankruptcy and financial health in 2009 provides a
contextual backdrop in which to place GM's decision to
lay-off the employees. And the financial data tends to make
more likely GM's argument that it discharged the
"novice-level" workers due to a reorganization that