Cesar N. Hernandez v. A. Constable, et al.

Summary

The United States District Court for the Eastern District of California rules on the parties’ motions in limine in a prisoner civil rights action alleging deliberate indifference to serious medical needs under the Eighth Amendment. The court grants or partially grants several motions concerning lay testimony, relevance, settlement negotiations, prior proceedings, and untimely declarations, while reserving ruling on other evidentiary issues until trial. The order is signed by United States District Judge Dena M. Coggins and dated October 17, 2025.

Holdings

1. Plaintiff's conviction may be used for impeachment under Federal Rule of Evidence 609, but the evidence must be limited to the fact that he was convicted of a crime punishable by more than one year of imprisonment and is currently serving a sentence for that conviction; the nature of the crime, sentence length, and conviction date may not be introduced.
2. Plaintiff may testify about his personal experiences, including what he felt and observed regarding his medical needs or condition, but may not offer opinions requiring scientific, technical, or other specialized knowledge.
3. Evidence or questioning concerning prison officials' marital status, family status, or personal relationships outside the prison setting is excluded as irrelevant to Plaintiff's claim and Defendants' defenses.
4. Evidence concerning unrelated prior complaints, incidents, disciplinary matters, or litigation involving a prison official is excluded for purposes other than impeachment; the court reserved ruling on whether particular evidence may be used for impeachment at trial.
5. Plaintiff may not introduce offers, compromises, or statements made during settlement negotiations to prove or disprove liability or the amount of a disputed claim, or for impeachment by prior inconsistent statement or contradiction, absent a showing that the evidence is offered for a permissible purpose under Rule 408(b).
6. Qualified immunity is a legal issue for the judge, not the jury, and Plaintiff may not argue that issue to the jury.
7. Plaintiff may not introduce any declaration that was not timely disclosed by the court's August 22, 2025 deadline; objections to the declarations of Ms. Takehara and Dr. Feinberg were reserved for trial.

Questions Presented

1. Whether Plaintiff's criminal conviction and prison disciplinary history should be excluded or limited for impeachment purposes.
2. Whether Plaintiff may testify as a lay witness about medical or mental-health matters requiring scientific, technical, or specialized knowledge.
3. Whether Plaintiff's medical and mental-health records should be excluded for lack of foundation or hearsay.
4. Whether evidence concerning prison officials' personal relationships, prior complaints, incidents, disciplinary matters, or unrelated litigation is relevant or admissible character evidence.
5. Whether evidence of settlement negotiations, prior summary-judgment proceedings, dismissed claims, qualified immunity, and untimely disclosed declarations may be presented to the jury.

Disposition

other