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Naranjo v. Luczak

United States District Court, M.D. Pennsylvania

April 20, 2018

ISAAC NARANJO, Plaintiff
v.
JAMES LUCZAK, et al., Defendants

          MEMORANDUM

          Christopher C. Conner, United States District Court Chief Judge

         Plaintiff 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.

         I. Factual Background & Procedural History

         Naranjo 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).

         Over 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 2-3).

         The corrections officers-James Luczak (“Luczak”), Ronald Pruitt (“Pruitt”), and Michael Skutack (“Skutack”), (collectively, “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.

         The 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).

         Naranjo thereafter filed the instant motion in limine. (Doc. 160). The motion is fully briefed and ripe for disposition.

         II. Discussion

         Naranjo 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.

         A. Relevancy

         Naranjo 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 omitted).

         There 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.

         This is 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 ยง 1.2 (2018). That same logic applies equally to the instant prior acts of self-harm. The ...


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