Lorrie Henderson v. Manoj Parbatsingh Ghayalod

Summary

The United States District Court for the District of Puerto Rico partially grants and partially denies Plaintiff Lorrie Henderson’s motion in limine in a Puerto Rico tort action arising from alleged domestic abuse. The court excludes evidence of Plaintiff’s prior drug use and specific prior domestic abuse and restraining orders, while allowing evidence of alcohol consumption and prior mental health treatment for limited purposes. The court denies without prejudice the request to exclude questions about schizophrenia and hallucinations and denies the request to present evidence of Defendant’s financial condition for punitive damages.

Holdings

1. Prior drug use may not be used to attack Plaintiff's general credibility, and Defendant failed to establish a special relevance for the evidence independent of character or propensity. Because Defendant did not show that Plaintiff used drugs when the alleged incidents occurred or provide evidence linking the drug use to her claimed symptoms and damages, testimony about the prior drug use was excluded.
2. The request to exclude testimony about Plaintiff's alcohol consumption was denied because Defendant asserted a genuine factual controversy concerning whether Plaintiff consumed alcohol on the day of the incident, making the evidence potentially relevant for permissible purposes.
3. Evidence of Plaintiff's prior mental-health treatment was admissible for purposes of evaluating preexisting conditions, alternative causes of emotional distress, symptom severity, causation, and damages, but it could not be used to generally attack Plaintiff's credibility.
4. The specific nature of the domestic abuse Plaintiff experienced in her first marriage and the restraining order obtained against her first ex-husband were excluded because any probative value was substantially outweighed by unfair prejudice. Defendant could inquire about the prior mental-health treatment and symptoms arising from the prior marriage, but not the specific abuse or restraining-order evidence.
5. The request to exclude questions about whether Plaintiff was schizophrenic or suffered from hallucinations was denied without prejudice because the request was premature and overbroad; any evidentiary issue could be addressed through a contemporaneous objection.
6. Plaintiff could not present evidence of Defendant's financial condition for punitive-damages purposes because Article 1538 of the Puerto Rico Civil Code caps punitive damages at the amount of compensatory damages, and the court's statutory interpretation superseded the earlier decision in Acevedo-Luis to the extent of any conflict.

Questions Presented

1. Whether evidence of Plaintiff's prior drug use should be excluded under Rules 404(b) and 403.
2. Whether evidence of Plaintiff's alcohol consumption should be excluded as irrelevant or otherwise inadmissible.
3. Whether evidence of Plaintiff's prior mental-health treatment was relevant to causation, damages, symptoms, or credibility.
4. Whether evidence concerning the specific domestic abuse and restraining order from Plaintiff's first marriage should be excluded because its probative value was substantially outweighed by unfair prejudice.
5. Whether questions concerning schizophrenia and hallucinations should be excluded before trial.
6. Whether Plaintiff could present evidence of Defendant's financial condition in support of her punitive-damages claim despite Puerto Rico's statutory punitive-damages cap.

Disposition

other