United States District Court, M.D. Pennsylvania
C. Carlson United States Magistrate Judge
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
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
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.
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.
Legal Standards-Motion in Limine
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.
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.
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,
“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.
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.' ...