Ridolfi v. State Farm Mutual Automobile Insurance Company

Filing 91

MEMORANDUM ORDER - IT IS ORDERED that the defendants motion inlimine (Doc. 59), is GRANTED, and the plaintiff is precluded from referring to State Farms net worth in the trial of this breach of contract claim. IT IS FURTHER ORDERED that the parties shall have a 59 Telephone Conference on 7/28/2017 at 01:00 PM before Magistrate Judge Martin C. Carlson to address some other pending motions in this case in advance of the pretrial conference. The plaintiff shall initiate the call.Signed by Magistrate Judge Martin C. Carlson on 7/25/2017. (sc)

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
TRACEY RIDOLFI,

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Plaintiff
v.
STATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY,
Defendant

Civil No. 1:15-CV-859
(Magistrate Judge Carlson)

MEMORANDUM ORDER
I.

Factual Background
This is an insurance dispute between Tracey Ridolfi and her insurer, State

Farm Mutual Automobile Insurance Company, relating to claims concerning State
Farm’s alleged refusal to provide underinsured motorist (UIM) coverage to Ridolfi.
Currently the sole remaining claim in this lawsuit is Ridolfi’s allegation that State
Farm’s conduct constitutes a breach of this insurance contract, this court having
previously dismissed Ridolfi’s claim that State Farm violated Pennsylvania’s bad
faith statute, 42 Pa. Cons. Stat. Ann. § 8371, by: (1) misstating the scope of its
coverage; (2) insisting upon a sworn statement from its insured; (3) unreasonably
delaying its investigation of this claim and requiring the production of multiple sets
of medical records; and (4) failing to keep Ridolfi fully informed in writing on the
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progress of her claim.
This case is set for trial on August 7, 2017. In anticipation of trial State Farm
has filed a series of motions in limine, including a motion in limine which seeks to
preclude Ridolfi from eliciting testimony regarding the net worth of the defendant.
(Doc. 59.) Ridolfi has not responded to this motion. Therefore, the motion is ripe for
resolution.
For the reasons set forth below, this motion in limine is GRANTED.
II.

Discussion
The Court is vested with broad inherent authority to manage its cases, which

carries with it the discretion and authority to rule on motions in limine prior to trial.
See Luce v. United States, 469 U.S. 38, 41 n.4 (1984); In re Japanese Elec. Prods.
Antitrust Litig., 723 F.2d 238, 260 (3d Cir. 1983), rev’d on other grounds sub nom.,
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (the court
exercises its discretion to rule in limine on evidentiary issues “in appropriate cases”).
Courts may exercise this discretion in order to ensure that juries are not exposed to
unfairly prejudicial, confusing or irrelevant evidence. United States v. Romano,
849 F.2d 812, 815 (3d Cir. 1988). Courts may also do so in order to “narrow the
evidentiary issues for trial and to eliminate unnecessary trial interruptions.”
Bradley v. Pittsburgh Bd. of Educ., 913 F.2d 1064, 1069 (3d Cir. 1990) (citation

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omitted). However, courts should be careful before doing so.
In considering motions in limine which call upon the Court to engage in
preliminary evidentiary rulings under Rule 403 of the Federal Rules of Evidence, we
begin by recognizing that these “evidentiary rulings [on motions in limine ] are
subject to the trial judge's discretion and are therefore reviewed only for abuse of
discretion ... Additionally, application of the balancing test under Federal Rule of
Evidence 403 will not be disturbed unless it is ‘arbitrary and irrational.’ ” Abrams v.
Lightolier Inc. 50 F.3d 1204, 1213 (3d Cir.1995) (citations omitted); see
Bernardsville Bd. of Educ. v. J.H., 42 F.3d 149, 161 (3d Cir.1994) (reviewing in
limine rulings for abuse of discretion). Yet, while these decisions regarding the
exclusion of evidence rest in the sound discretion of the district court, and will not be
disturbed absent an abuse of that discretion, the exercise of that discretion is guided
by certain basic principles.
One of the key guiding principles is reflected in the philosophy which shapes
the rules of evidence. The Federal Rules of Evidence can aptly be characterized as
evidentiary rules of inclusion, which are designed to broadly permit fact-finders to
consider pertinent factual information while searching for the truth. The
inclusionary quality of the rules, is embodied in three cardinal concepts. The first of
these concepts is Rule 401's definition of relevant evidence. Rule 401 defines what is

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relevant in an expansive fashion, stating:

“Relevant evidence” means evidence having any tendency
to make the existence of any fact that is of consequence to
the determination of the action more probable *197 or less
probable than it would be without the evidence.
Fed. R. Evid. 401.
Adopting this view of relevance it has been held that: “Under [Rule] 401,
evidence is relevant if it has ‘any tendency to make the existence of any fact that is of
consequence to the determination of the action more probable or less probable than it
would be without the evidence.’ [Therefore] ‘It follows that evidence is irrelevant
only when it has no tendency to prove the fact. Thus the rule, while giving judges
great freedom to admit evidence, diminishes substantially their authority to exclude
evidence as irrelevant.’ ” Frank v. County of Hudson, 924 F. Supp. 620, 626
(D.N.J.1996) citing Spain v. Gallegos, 26 F.3d 439, 452 (3d Cir.1994) (quotations
omitted).
This quality of inclusion embraced by the Federal Rules of Evidence is further
buttressed by Rule 402, which generally defines the admissibility of relevant
evidence in sweeping terms, providing that:
All relevant evidence is admissible, except as otherwise
provided by the Constitution of the United States, by Act
of Congress, by these rules, or by other rules prescribed by
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the Supreme Court pursuant to statutory authority.
Evidence which is not relevant is not admissible.
Fed. R. Evid. 402.
Thus, Rule 402 expressly provides that all “[r]elevant evidence will be
admissible unless the rules of evidence provide to the contrary.” United States v.
Sriyuth, 98 F.3d 739, 745 (3d Cir.1996) (citations omitted). These principles
favoring inclusion of evidence are, however, subject to some reasonable limitations.
Thus, Rule 403, provides grounds for exclusion of some potentially irrelevant but
highly prejudicial evidence, stating that:

Although relevant, evidence may be excluded if its
probative value is substantially outweighed by the danger
of unfair prejudice, confusion of the issues, or misleading
the jury, or by considerations of undue delay, waste of
time, or needless presentation of cumulative evidence.
Fed. R. Evid. 403 .
By permitting the exclusion of relevant evidence only when its probative
value is “substantially outweighed” by other prejudicial factors, Rule 403
underscores the principle that, while evidentiary rulings rest in the sound discretion
of the court, that discretion should consistently be exercised in a fashion which
favors the admission of relevant proof unless the relevance of that proof is
substantially outweighed by some other factors which caution against admission.
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In the instant case, exercising our discretion, we conclude that evidence of
State Farm’s net worth is properly excluded from the trial of this case. Presently the
sole remaining claim in this litigation is a breach of contract claim by Ridolfi against
State Farm. The only tangential, conceivable relevance that evidence of State
Farm’s net worth might have to this litigation would be as evidence supporting a
punitive damages claim. See TVT Records v. Island Def Jam Music Grp., 412 F.3d
82 (2d Cir. 2005). However, it is well-settled under Pennsylvania law that: “
‘punitive damages are not recoverable in an action based solely on breach of
contract.’ Thorsen v. Iron & Glass Bank, 328 Pa.Super. 135, 476 A.2d 928, 932
(Pa.Super.Ct.1984); Johnson v. Hyundai Motor Am., 698 A.2d 631, 639
(PaSuper.Ct.1997).” Samuel-Bassett v. KIA Motors Am., Inc., 357 F.3d 392, 402 (3d
Cir. 2004). Since punitive damages are not recoverable in this lawsuit, interjection of
this irrelevant evidence would be highly prejudicial and could lead to juror
confusion/ Therefore, this net worth evidence is not relevant to any of the issues
properly before the jury and should be excluded from the trial of this case.
An appropriate order follows.
III.

Order
For the forgoing reasons, IT IS ORDERED that the defendant’s motion in

limine (Doc. 59), is GRANTED, and the plaintiff is precluded from referring to State
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Farm’s net worth in the trial of this breach of contract claim. IT IS FURTHER
ORDERED that the parties shall have a telephonic conference with the court on July
28, 2017 at 1:00 p.m. to address some other pending motions in this case in advance
of the pretrial conference. The plaintiff shall initiate the call, ensuring that all parties
are on the telephone line, before contacting the Court at telephone number
717-614-4120.

/s/ Martin C. Carlson
Martin C. Carlson
United States Magistrate Judge
Dated: July 25, 2017

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