Michael R. Capshaw v. WERCS

Summary

The Supreme Court of Wyoming reviewed a writ petition challenging a district court order barring evidence and argument concerning alleged mismanagement by the employer. The court held that the order effectively prevented the employee from presenting his theory that his termination was pretextual and therefore constituted an abuse of discretion. The order was reversed and the case was remanded.

Holdings

1. The district court abused its discretion by categorically excluding evidence concerning WERCS's alleged mismanagement because the evidence was relevant to whether Capshaw had a good-faith basis for criticizing management and whether WERCS's stated reasons for terminating him were pretextual.
2. The trial court may control the amount and presentation of relevant evidence, including excluding cumulative or confusing evidence, but it may not categorically prevent the parties from presenting sufficient admissible evidence bearing on whether Capshaw had a good-faith basis for criticizing WERCS's management.
3. The signed written order controls over a prior oral order when the written order has been entered.

Questions Presented

1. Whether the district court abused its discretion by granting a motion in limine that barred Capshaw from mentioning or presenting evidence concerning his allegations of WERCS's mismanagement.
2. Whether the motion-in-limine order materially prejudiced Capshaw by preventing him from presenting the evidence central to his pretextual-discharge and breach-of-contract theories.
3. Whether the appellate court could review the motion-in-limine ruling before trial.

Disposition

reversed_and_remanded