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International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America UAW v. General Motors, LLC

United States District Court, E.D. Michigan, Southern Division

October 27, 2016

INTERNATIONAL UNION, UNITED AUTOMOBILE, AEROSPACE, AND AGRICULTURAL IMPLEMENT WORKERS OF AMERICA UAW, AND ITS LOCAL 1869, Plaintiffs,
v.
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.

         Plaintiffs 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 motion.

         BACKGROUND

         Gerald 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.

         LEGAL STANDARD

         "Although 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.

         The 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).

         The 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) (quotations omitted).

         DISCUSSION

         I. UAW's Motion in Limine

         UAW 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.

         A. GM's 2009 Bankruptcy

         UAW 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.

         The 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 ...


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