Lombardi v. City of Groton
599 A.2d 388, 1991 Conn. App. LEXIS 399, 26 Conn. App. 157 (1991)
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Rule of Law:
A trial court has broad discretion to exclude evidence of a plaintiff's prior remote misdemeanor convictions if their probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury.
Facts:
- The plaintiff operated a catering truck near the Electric Boat Division in Groton.
- On June 9, 1987, Groton police officers Cindy Grenier and David Bailey initiated a traffic stop of the plaintiff's vehicle for an expired emissions sticker.
- During the stop, Bailey allegedly slapped the plaintiff's wallet to the ground and shoved him against his truck.
- Grenier and a third officer, Ronald Jenkins, who had arrived on the scene, joined Bailey in throwing the plaintiff to the ground.
- Bailey handcuffed the plaintiff and transported him to the Groton police station.
- At the station, Bailey allegedly threw the plaintiff against a steel cell plate.
- The plaintiff was issued a motor vehicle summons for the expired sticker.
- As a result of the encounter, the plaintiff suffered physical injuries, including bruises, contusions, and a fracture of a lumbar spine vertebra.
Procedural Posture:
- The plaintiff filed a civil action in a trial court against police officers David Bailey, Ronald Jenkins, and Cindy Grenier.
- The case proceeded to a jury trial.
- The jury found for the plaintiff, awarding him $125,000 in compensatory damages and varying amounts of punitive damages against each officer.
- The trial court also awarded the plaintiff attorney's fees.
- The defendants, Bailey, Jenkins, and Grenier, appealed the judgment to the Appellate Court of Connecticut.
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Issue:
Did the trial court abuse its discretion by excluding evidence of the plaintiff's remote misdemeanor convictions, which were offered to show bias or custom and to contest the plaintiff's claim of emotional distress?
Opinions:
Majority - Heiman, J.
No. The trial court did not abuse its discretion by excluding the evidence of the plaintiff's prior convictions. Trial courts are given liberal discretion in determining the relevancy of evidence. The plaintiff's prior convictions were all for misdemeanors, making them inadmissible for impeaching his credibility under state law. Furthermore, the convictions were remote, occurring between eleven and twenty-five years prior to the trial, and did not involve the defendant officers. The court reasonably concluded that admitting this evidence would distract the jury from the central issues of the case—the officers' conduct. The defendants also failed to establish a factual basis for their claim that the prior arrests were relevant to the plaintiff's emotional damages, as their own expert could not support the theory that a person with prior arrests would be less traumatized, leading them to abandon this offer of proof.
Analysis:
This decision reinforces the significant deference appellate courts give to trial courts on evidentiary rulings. It highlights the principle that evidence, particularly of prior bad acts or convictions, must have more than slight relevance to be admissible, especially when it carries a high risk of unfair prejudice. The ruling protects plaintiffs in civil rights cases from having their character attacked with stale and unrelated misdemeanor convictions, ensuring the jury's focus remains on the defendants' conduct that gave rise to the lawsuit.
