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Hong v. Key Safety Restraint Systems, Inc.

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

June 5, 2019

GUANG “BRADLEY”HONG, Plaintiff,
v.
KEY SAFETY RESTRAINT SYSTEMS, INC., ET AL., Defendants.

          STEPHANIE DAWKINS DAVIS UNITED STATES MAGISTRATE JUDGE.

          OPINIONANDORDERDENYINGDEFENDANTS'MOTIONINLIMINE [#43]

          HON. GERSHWIN A. DRAIN UNITED STATES DISTRICT COURT JUDGE.

         I. Introduction

         Present before the Court is Defendants Key Safety Restraint Systems, Inc. (“KSS”) and Joe Perkins' Motion in Limine. Dkt. No. 43. For the reasons set forth below, the Court will DENY the Motion [#43].

         II. Background

         Plaintiff Bradley Hong, a Chinese-American United States Citizen, initiated this employment discrimination suit after he was fired by Defendant KSS during a Reduction in Force (“RIF”) in October 2017. Plaintiff alleges he was wrongfully terminated on account of his race. In support of his claims, Plaintiff asserts that his supervisor, Defendant Joe Perkins, regularly made disparaging remarks directed at people of Chinese ethnicity during staff meetings. Further, that Perkins acted on his animus towards the Chinese to terminate Plaintiff. While Defendants do not refute Perkins' statements, they argue that he had no role or influence over the decision to fire Plaintiff. Instead, they maintain that Yuxin Tang -- KSS's interim President -- made this decision alone. Therefore, Defendants seek to prevent Plaintiff from introducing Perkins' statements at trial before establishing their relevance.

         III. Legal Standard

         A motion in limine refers to “any motion, whether made before or during trial, to exclude anticipated prejudicial evidence before the evidence is actually offered.” Luce v. United States, 469 U.S. 38, 40, n.2 (1984). The purpose of these motions is “to narrow the issues remaining for trial and to minimize disruptions at trial.” United States v. Brawner, 173 F.3d 966, 970 (6th Cir. 1999). In disposing of a motion in limine, the guiding principle is to “ensure evenhanded and expeditious management of trials.” Ind. Ins. Co. v. GE, 326 F.Supp.2d 844, 846 (N.D. Ohio, 2004).

         IV. Discussion

         Defendants argue that before Plaintiff can introduce evidence of Defendant Perkins' alleged anti-Chinese remarks, he should be required to lay a foundation that the remarks are relevant. Specifically, Defendants ask the Court to require Plaintiff to demonstrate the following:

1. Defendant Perkins significantly contributed to the decision to eliminate Plaintiff's position;
2. The remarks were related to the decision-making process;
3. The remarks were more than merely vague, ambiguous, or ...

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