Patricia McBreairty, as Personal Representative of the Estate of Shawn McBreairty v. Brewer School Department, et al.

Summary

The United States District Court for the District of Maine dismissed without prejudice the defendants’ motion in limine seeking to exclude evidence of punitive damages and seeking judgment as a matter of law on the punitive damages claims. The court concluded that the bifurcated trial structure and the absence of specifically identified evidence made a pretrial ruling on admissibility premature, and that a Rule 50 motion was untimely before trial evidence had been presented. The defendants may renew their arguments at the appropriate stage of trial.

Holdings

1. The motion to exclude all evidence of punitive damages was dismissed without prejudice because defendants did not identify specific testimony or exhibits for exclusion and some evidence could be relevant to both liability and punitive damages.
2. The request for judgment as a matter of law was dismissed without prejudice because a Rule 50(a) motion is premature before the nonmoving party has been fully heard on the issue during a jury trial.
3. The court declined to entertain the request as an early motion to dismiss or summary-judgment motion because such dispositive motions were subject to the scheduling order's deadlines and the request was too late.

Questions Presented

1. Whether the court should preclude all evidence relating to punitive damages before trial.
2. Whether defendants could obtain judgment as a matter of law on the punitive-damages claims before the presentation of evidence at trial.
3. Whether evidence solely relevant to punitive damages, such as a defendant's wealth, should be admitted during the liability and compensatory-damages phase of a bifurcated trial.

Disposition

dismissed