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LEGAL INFORMATION INSTITUTE -- CORNELL LAW SCHOOL
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SPRINT/UNITED MANAGEMENT CO. v. MENDELSOHN (06-1221 Syllabus)
http://www.law.cornell.edu/supct/html/06-1221.ZS.html
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SPRINT/UNITED MANAGEMENT CO. v. MENDELSOHN (No. 06-1221)
Web-accessible at:
http://www.law.cornell.edu/supct/html/06-1221.ZS.html
Argued: December 3, 2007 -- Decided: February 26, 2008
Opinion author: Thomas
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In respondent Mendelsohn's age discrimination case, petitioner
Sprint moved in limine to exclude the testimony of former
employees alleging discrimination by supervisors who had
no role in the employment decision Mendelsohn challenged,
on the ground that such evidence was irrelevant to the
case's central issue, see Fed. Rules Evid. 401, 402, and
unduly prejudicial, see Rule 403. Granting the motion,
the District Court excluded evidence of discrimination
against those not "similarly situated" to Mendelsohn. The
Tenth Circuit treated that order as applying a per se rule
that evidence from employees of other supervisors is irrelevant
in age discrimination cases, concluded that the District
Court abused its discretion by relying on the Circuit's
Aramburu case, determined that the evidence was relevant
and not unduly prejudicial, and remanded for a new trial.
Held: The Tenth Circuit erred in concluding that the District
Court applied a per se rule and thus improperly engaged
in its own analysis of the relevant factors under Rules
401 and 403, rather than remanding the case for the District
Court to clarify its ruling. Pp. 4-9.
(a) In deference to a district court's familiarity with
a case's details and its greater experience in evidentiary
matters, courts of appeals uphold Rule 403 rulings unless
the district court has abused its discretion. Here, the
Tenth Circuit did not accord due deference to the District
Court. The District Court's two-sentence discussion of
the evidence neither cited nor gave any other indication
that the decision relied on Aramburu or suggestedthat the
court applied a per se rule of inadmissibility. Neither
party's submissions to the District Court suggested that
Aramburu was controlling. That court's use of the same
"similarly situated" phrase that Aramburu used cannot be
presumed to indicate adoption of Aramburu's analysis, for
the District Court was addressing a very different kind
of evidence here. And the nature of Sprint's argument was
not that the particular evidence was never admissible,
but only that such evidence lacked sufficient probative
value in this case to be relevant or outweigh prejudice
and delay. Pp. 4-7.
(b) Because of the Tenth Circuit's error, it went on to
assess the relevance of the evidence itself and conduct
its own balancing of probative value and potential prejudicial
effect when it should have allowed the District Court to
make these determinations in the first instance, explicitly
and on the record. Pp. 7-8.
466 F. 3d 1223, vacated and remanded.
Thomas, J., delivered the opinion for a unanimous Court.
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