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State Farm Fire & Casualty Co. v. Miller

United States District Court, M.D. Pennsylvania

March 7, 2017

STATE FARM FIRE & CASUALTY CO., Plaintiff
v.
DAVID MILLER, Defendant

          MEMORANDUM OPINION

          Martin C. Carlson United States Magistrate Judge

         I. INTRODUCTION

         This civil action comes before us for resolution of a motion in limine (Doc. 22), filed by the plaintiff, State Farm Fire & Casualty Company, which seeks to define the scope of damages evidence in this insurance subrogation case. With respect to this motion, the pertinent facts are as follows:

         This is a subrogation action brought by State Farm against David Miller arising out of a fire damage claim relating to an October 9, 2014 accidental fire at 431 and 433 3d. Street, Steelton, Pennsylvania. On October 9, 2014, David Miller resided at 433 3d. Street. State Farm's insured, in turn, lived at 431 3d. Street. It is alleged that, on October 9, 2014, a kitchen fire started at Miller's residence due to the defendant's negligence. That fire then spread to the adjoining property causing damages which State Farm was obliged under its insurance policy to reimburse for its insured. These insurance reimbursements made by State Farm allegedly totaled approximately $255, 000 and included repair costs for damages to 431 3d. Street, which amounted to $107, 545.00. It is this component of the payments made by State Farm, which it seeks to recover from Miller in this subrogation action, that is the subject of the instant motion in limine.

         In its motion, State Farm argues that, under Pennsylvania law, the proper measure of damages in this property damage case is the cost of repair for the property, $107, 545. Asserting a belief that Miller may attempt to introduce evidence relating to the depreciated value, or actual cash value of the property located at 431 3d. Street, evidence which State Farm argues would confuse the jury, State Farm seeks a pretrial ruling excluding any such evidence from the trial of this case. (Docs. 22 and 23) For his part, Miller has responded to this motion in limine by conceding that the jury should not be presented with “bald valuations made by some insurance adjuster, ” but argues that in some instances measures of loss beyond repair costs may be appropriate, and seeks leave to present such evidence of alternate loss measurements at trial.

         Upon consideration of the positions of the parties, for the reasons set forth below, the motion in limine will be granted, in part, and denied, in part, and we will conditionally preclude the defendant from presenting evidence regarding matters extraneous to the cost of repair, unless the defendant makes an offer of proof which shows that the proffered evidence satisfies the alternate measure of damages accepted by Pennsylvania courts; that is, the defendant proffers evidence which tends to show that the market value of the property was less than the cost of repairs.

         II. DISCUSSION

         A. Legal Standards-Motion in Limine

         The Court is vested with broad inherent authority to manage its cases, which carries with it the discretion and authority to rule on motions in limine prior to trial. See Luce v. United States, 469 U.S. 38, 41 n.4 (1984); In re Japanese Elec. Prods. Antitrust Litig., 723 F.2d 238, 260 (3d Cir. 1983), rev'd on other grounds sub nom., Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (the court exercises its discretion to rule in limine on evidentiary issues “in appropriate cases”). Courts may exercise this discretion in order to ensure that juries are not exposed to unfairly prejudicial, confusing or irrelevant evidence. United States v. Romano, 849 F.2d 812, 815 (3d Cir. 1988). Courts may also do so in order to “narrow the evidentiary issues for trial and to eliminate unnecessary trial interruptions.” Bradley v. Pittsburgh Bd. of Educ., 913 F.2d 1064, 1069 (3d Cir. 1990) (citation omitted). However, courts should be careful before doing so.

         In considering motions in limine which call upon the Court to engage in preliminary evidentiary rulings under Rule 403 of the Federal Rules of Evidence, we begin by recognizing that these “evidentiary rulings [on motions in limine] are subject to the trial judge's discretion and are, therefore, reviewed only for abuse of discretion ... Additionally, application of the balancing test under Federal Rule of Evidence 403 will not be disturbed unless it is ‘arbitrary and irrational.' ” Abrams v. Lightolier Inc. 50 F.3d 1204, 1213 (3d Cir.1995) (citations omitted); see Bernardsville Bd. of Educ. v. J.H., 42 F.3d 149, 161 (3d Cir.1994) (reviewing in limine rulings for abuse of discretion). Yet, while these decisions regarding the exclusion of evidence rest in the sound discretion of the district court, and will not be disturbed absent an abuse of that discretion, the exercise of that discretion is guided by certain basic principles.

         One of the key guiding principles is reflected in the philosophy which shapes the rules of evidence. The Federal Rules of Evidence can aptly be characterized as evidentiary rules of inclusion, which are designed to broadly permit fact-finders to consider pertinent factual information while searching for the truth. The inclusionary quality of the rules, and their permissive attitude towards the admission of evidence, is embodied in three cardinal concepts. The first of these concepts is Rule 401's definition of relevant evidence. Rule 401 defines what is relevant in an expansive fashion, stating:

“Relevant evidence” means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable *197 or less probable than it would be without the evidence.

Fed. R. Evid. 401.

         Adopting this broad view of relevance it has been held that: “Under [Rule] 401, evidence is relevant if it has ‘any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.' [Therefore] ‘It follows that evidence is irrelevant only when it has no tendency to prove the fact. Thus the rule, while giving judges great freedom to admit evidence, diminishes substantially their authority to exclude evidence as irrelevant.' ...


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