Ridolfi v. State Farm Mutual Automobile Insurance Company
MEMORANDUM ORDER - IT IS ORDERED that the defendants motion in limine (Doc. 58), is GRANTED, and the plaintiff is precluded from referring to the amount of the premiums paid to State Farm in the trial of this breach of contract claim. 58 Signed by Magistrate Judge Martin C. Carlson on 7/27/2017. (sc)
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
STATE FARM MUTUAL
Civil No. 1:15-CV-859
(Magistrate Judge Carlson)
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
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 amounts of the premiums
she paid for the insurance policy which is at issue in this case. (Doc. 58.) This
motion in limine is fully briefed by the parties, (Docs. 69 and 81) and is, therefore,
ripe for resolution.
For the reasons set forth below, this motion in limine is GRANTED.
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
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
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
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
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.
In the instant case, exercising our discretion, we conclude that evidence of the
amount of the premiums paid on this insurance policy is properly excluded from the
trial of this case. We reach this result mindful that courts have come to differing
conclusions on this precise issue. Compare Noone v. Progressive Direct Ins. Co.,
No. 3:12CV1675, 2013 WL 8367579, at *2 (M.D. Pa. May 28, 2013)(denying
motion in limine) with Lucca v. Geico Ins. Co., No. CV 15-4124, 2016 WL 3632717,
at *2 (E.D. Pa. July 7, 2016)(granting motion in limine). On this score, we find the
rationale of the court in Lucca to be more persuasive. In Lucca, the district court
granted a motion in limine excluding evidence relating to the amount of the
premiums paid by the plaintiff on an insurance policy in a case involving a UIM
claim, noting that:
The Court acknowledges that the bar for relevance is low. However, the
amounts of the . . . paid premiums, facts that are undisputed and
therefore not for the jury to decide, do not even reach that low bar. The
only issue for the jury to decide in this matter is the extent of [the
plaintiff’s] injuries from the accident. That . . . [the plaintiff or someone
acting on plaintiff’s behalf] paid a certain amount in premiums for the
policy does not have “any tendency to make [any fact at issue in this
case] more or less probable than it would be without the evidence.” See
Fed. R. Evid. 401.
Lucca v. Geico Ins. Co., No. CV 15-4124, 2016 WL 3632717, at *3 (E.D. Pa. July 7,
We agree. As in Lucca, presently the sole remaining issue in this litigation is a
breach of contract claim by Ridolfi against State Farm. As to this claim, there is no
allegation or defense raised by State Farm that Ridolfi is not entitled to recover
under this policy because she has failed to pay premiums on the policy. Indeed, it
seems undisputed that Ridolfi was current in her policy payments. While it has been
suggested that payment of premiums has some limited relevance to the breach of
contract claim since it shows that the plaintiff has complied with her contractual
obligations, or establishes that consideration was received by State Farm in return
for its agreement to insure Ridolfi, see Rodkey v. Progressive Direct Ins. Co., No.
3:16CV454, 2016 WL 7159307, at *1 (M.D. Pa. Dec. 8, 2016), that fact can be
established either by stipulation or by presentation of uncontradicted evidence that
Ridolfi has paid all of the premiums owed on the policy. The amount of those
premium payments, however, is not necessary or relevant to satisfy this element of
proof, and could have a misleading effect for the jury since it might imply some false
measure of damages in this case, a measure of damages unrelated to Ridolfi’s
compensable recovery under her insurance policy with State Farm. Thus, this
specific proof seems both irrelevant, and potentially prejudicial and confusing for
For her part Ridolfi attempts to overcome these hurdles of relevance,
prejudice and potential confusion by arguing that the amount of the policy limits
may be relevant to the breach of contract claim, since she alleges a breach of the duty
of good faith under this contract by virtue of State Farm’s misstatement regarding
the policy limits. However, Ridolfi does not persuasively explain why the amount of
the premiums paid would be relevant to this aspect of her case, and we find that
whatever relevance misstatement of the policy limits has here, an issue we will
decide in another motion in limine, that dispute does not legally, or logically, open
the door to introduction of evidence concerning the amounts of the premiums paid
on this policy. Since interjection of this evidence could lead to juror confusion, and
is not relevant to any of the issues properly before the jury, this evidence should be
excluded from the trial of this case.
An appropriate order follows.
For the forgoing reasons, IT IS ORDERED that the defendant’s motion in
limine (Doc. 58), is GRANTED, and the plaintiff is precluded from referring to the
amount of the premiums paid to State Farm in the trial of this breach of contract
/s/ Martin C. Carlson
Martin C. Carlson
United States Magistrate Judge
Dated: July 27, 2017
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