Sawant v. Ramsey
A court can bar the admission of evidence, if potential prejudice from the evidence is greater than any probative value. The plaintiffs filed a motion in limine and requested that the court bar the admission of evidence that the Securities and Exchange Commission 1.) investigated the defendants, Geoffrey Ramsey, and Host America; and 2.) recommended that no enforcement action take place. The plaintiffs maintained that the jury could conclude, based on the SEC's report, that the defendants did not violate securities laws and that the prejudice from the report was greater than any probative value. The District Court agreed. "[T]he prejudicial impact," wrote the court, "far exceeds any probative value." The probative value of the report is minimal, because it does not adequately explain the SEC's rationale, which might have included a prosecutorial decision to prioritize other matters, a decision that wrongdoing had been corrected or a lack of sufficient resources. Admission of the report, added the court, could usurp the jury's role as the factfinder and "cause substantial unfair prejudice against the Plaintiffs." The plaintiffs are entitled to have the jury examine the evidence and decide for itself whether the defendants violated securities laws. The court granted the plaintiffs' motion to preclude the admission of the SEC's report. The court also found that serious health conditions that restrict the ability to travel could constitute good cause, to permit the plaintiffs to testify via live video conference, as an alternative to in-court testimony. The court ordered the plaintiffs to provide up-to-date medical information.