United States District Court, M.D. Pennsylvania
Christopher C. Conner, United States District Court Chief
Isaac Naranjo (“Naranjo”) filed a pretrial motion
in limine (Doc. 160) seeking to exclude certain
other-act evidence at his upcoming civil rights trial. He
also filed several unrelated motions involving his pretrial
memorandum. (Docs. 158, 162). For the following reasons, the
court will deny Naranjo's motion in limine, and
will grant his other motions.
Factual Background & Procedural History
is a former inmate of the State Correctional Institution in
Dallas, Pennsylvania (“SCI Dallas”). (Doc. 13 at
1). He currently is incarcerated in a different state
correctional facility. (See, e.g., Doc. 164
at 3). In July of 2011, Naranjo commenced this pro
se civil rights action pursuant to 42 U.S.C. §
1983, in which he alleged various constitutional violations
by SCI Dallas officials and personnel. (Doc. 1).
the extensive course of litigation, Naranjo's claims have
been significantly circumscribed. (See generally
Docs. 8, 9, 95, 96). The only remaining claims stem from an
incident that occurred at SCI Dallas on February 11, 2011.
(Doc. 95 at 2). According to Naranjo, on that day three SCI
Dallas corrections officers assaulted him in retaliation for
his involvement as a witness in another inmate's
grievance investigation and related lawsuit. (Id. at
corrections officers-James Luczak (“Luczak”),
Ronald Pruitt (“Pruitt”), and Michael Skutack
“defendants”)-deny Naranjo's allegations, and
contend that Naranjo's injuries were self-inflicted.
(Id. at 3-4). In December of 2015, the four
remaining defendants moved for summary judgment on all
pending claims except Naranjo's Eighth Amendment
excessive force claim. (Doc. 79). The Honorable William W.
Caldwell granted in part and denied in part defendants'
motion. (Docs. 95, 96). Specifically, Judge Caldwell held
that Naranjo's First Amendment retaliation claim based on
the alleged assault survived Rule 56 scrutiny. (Doc. 95 at
7-9). Judge Caldwell also dismissed the fourth defendant,
Charlie McKeown, leaving only Luczak, Pruitt, and Skutack as
defendants. (Doc. 96 at 1). The Eighth Amendment excessive
force and First Amendment retaliation claims against Luczak,
Pruitt, and Skutack are the only claims remaining for trial.
court secured pro bono counsel to represent Naranjo.
(Doc. 140). In June of 2017, this case was reassigned from
Judge Caldwell to the undersigned. Trial was set for January
8, 2018, (Doc. 148), but was postponed at defense
counsel's request. (Doc. 152 at 2-3). In the interim,
Naranjo moved to proceed pro se, (Docs. 153, 154),
and Naranjo's pro bono counsel moved to
withdraw, (Doc. 156). The court granted these motions and
designated Naranjo as proceeding pro se. (Doc. 157).
thereafter filed the instant motion in limine. (Doc.
160). The motion is fully briefed and ripe for disposition.
seeks to exclude certain evidence that he believes defendants
intend to introduce during the upcoming trial. (Id.
at 2). Specifically, Naranjo asserts that defendants will
attempt to admit his prior convictions and those of his
witnesses, his prior disciplinary records, and irrelevant
medical records. (Id. at 3-6). In response,
defendants aver that the only other-act evidence they intend
to proffer at trial relates to Naranjo's prior acts of
self-harm, which include “banging his head on a wall,
using his finger to cause nose bleeds, and trying to hang
himself.” (Doc. 163 at 3). Defendants posit that such
evidence is admissible under Federal Rule of Evidence
404(b)(2). (Id. at 3-6). We address the parties'
arguments concerning admissibility of Naranjo's prior
acts of self-harm seriatim.
first contends that the prior act evidence is irrelevant.
Evidence is relevant when it tends to “make a fact more
or less probable than it would be without the evidence”
and that fact is consequential to the outcome of the case.
Fed.R.Evid. 401. Rule 401's definition of relevant
evidence is “very broad” and “does not
raise a high standard.” Moyer v. United Dominion
Indus., Inc., 473 F.3d 532, 544 (3d Cir. 2007) (citation
is little doubt that the other-act evidence purportedly
demonstrating that Naranjo inflicted injuries on himself in
the past is “relevant” to the current claims. If
believed, the fact that Naranjo caused similar self-harm in
the past makes the fact that he caused self-harm in the
instant matter-a consequential fact in the outcome of this
case-“more . . . probable than it would be without the
evidence.” Fed.R.Evid. 401.
almost always the case with similar other-act evidence. As
the Third Circuit has explained, prior convictions are
indisputably relevant for purposes of Rule 401, at least
insofar as prior offenses make it more likely that a criminal
defendant would commit the same crime again. United
States v. Caldwell, 760 F.3d 267, 274 (3d Cir. 2014);
see also David P. Leonard, The New Wigmore: A
Treatise on Evidence: Evidence of Other Misconduct and
Similar Events § 1.2 (2018). That same logic applies
equally to the instant prior acts of self-harm. The ...