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Rodriguez v. Miami-Dade County

United States District Court, M.D. Florida, Tampa Division

July 18, 2018

NADIA RODRIGUEZ, Plaintiff,
v.
MIAMI-DADE COUNTY, Defendant.

          ORDER

          AMANDA ARNOLD SANSONE UNITED STATES MAGISTRATE JUDGE

         This Order follows Nadia Rodriguez's motion in limine (Doc. 96), Miami-Dade County's motion in limine (Doc. 102), and Ms. Rodriguez's motion for judicial notice (Doc. 105).[1] The court will address the exhibits at issue in each motion in turn.

         A. Plaintiff's Exhibit 19

         Plaintiff's Exhibit 19, which the parties entitle “MDC appeal employment decision, ” is an automated appeal concerning Ms. Rodriguez's employment at Miami-Dade County. (Doc. 44-1, p. 29). Although the circumstances leading to the automated appeal are unclear, under a section entitled “Appeal Explanation, ” the automated appeal states: “The claimant was discharged for failing to meet the employer's job performance requirement.” (Id.). The claimant listed on the automated appeal is Ms. Rodriguez. (Doc. 44-1, p. 29).

         Miami-Dade County argues Plaintiff's Exhibit 19 should be excluded because it is irrelevant to the claims and defenses in this case. (Doc. 102, p. 1). Miami-Dade County also argues any probative value to the exhibit is outweighed by the danger of confusing or misleading the jury. (Id. at 2-5). In response, Ms. Rodriguez argues case law supports finding unemployment decisions, like Plaintiff's Exhibit 19, admissible. (Doc. 109, pp. 3-4).

         Under Federal Rule of Evidence 401, evidence is relevant if it has any tendency to make a fact more or less probable and that fact is “of consequence in determining the action.” Fed.R.Evid. 401. Relevant evidence is generally admissible. Fed.R.Evid. 402. The court, however, can exclude relevant evidence “if its probative value is substantially outweighed by a danger of” unfair prejudice, confusing the issues, or misleading the jury. Fed.R.Evid. 403.

         Decisions awarding unemployment compensation under Florida law are irrelevant to determining whether an employer retaliated or discriminated against an employee. Dagness v. Target Media Partner Operating Co., LLC, No. 1:15-CV-23989-UU, 2016 WL 10647255, at *4 (S.D. Fla. Nov. 14, 2016).

         Here, Ms. Rodriguez failed to explain the circumstances that led to the automated decision she wishes to introduce into evidence. Even if Ms. Rodriguez sufficiently explained the circumstances surrounding Plaintiff's Exhibit 19, the exhibit is not relevant to any claim or defense in this case. The issues the jury must determine are whether Miami-Dade County discriminated or retaliated against Ms. Rodriguez. (Doc. 80). Whether Ms. Rodriguez was entitled to unemployment compensation under Florida law is irrelevant. Even if Plaintiff's Exhibit 19 was relevant, the danger of confusing or misleading the jury if Ms. Rodriguez introduced the automated decision into evidence substantially outweighs any probative value the exhibit might have. Therefore, Miami-Dade County's motion to exclude Plaintiff's Exhibit 19 is granted.

         B. Plaintiff's Exhibit 20

         Plaintiff's Exhibit 20 is a “Decision of Appeals Referee” from the Florida Department of Economic Opportunity (FDEO). (Doc. 105-1). In its decision, the FDEO affirmed Miami-Dade County's automated appeal and found Mr. Rodriguez entitled to unemployment benefits. (Id.).

         Miami-Dade County argues the FDEO's decision is irrelevant and any probative value the FDEO's decision might have is substantially outweighed by the danger of confusing or misleading the jury. (Docs. 102, 108).

         Ms. Rodriguez argues Miami-Dade County had the opportunity to appeal the FDEO's decision finding her entitled to employment compensation, but Miami-Dade County failed to do so. (Doc. 109, p. 3). Ms. Rodriguez claims the FDEO's decision is relevant because Miami-Dade County's position in this case is that Ms. Rodriguez engaged in misconduct, which led to termination; therefore, the FDEO's decision is relevant to Miami-Dade County's defense. (Id.). Ms. Rodriguez requests the court to take judicial notice of the FDEO's decision as an adjudicative fact under Federal Rule of Evidence 201. (Doc. 105).

         Like other unemployment compensation determinations, FDEO appeals referees' decisions are irrelevant to determining whether an employer discriminated or retaliated against an employee. Gray v. Fla. Dept. of Juvenile Justice, No. 3:06-CV-990-J-20MCR, 2008 WL 11336339, at *2 (M.D. Fla. Feb. 21, 2008) (citation omitted); see also Muller-Davila v. Care Placement Home Health Agency, Inc., No. 8:17-CV-505-T-26AAS, 2018 WL 1565457, at *3 (M.D. Fla. Mar. 30, 2018) (declining to consider appeals referee decision denying reemployment assistance benefits in a Title VII case).

         Here, the FDEO appeals referee's decision that Ms. Rodriguez was entitled to unemployment benefits is irrelevant to whether Miami-Dade County discriminated or retaliated against Ms. Rodriguez. Even if the appeals referee's decision was relevant, the danger of misleading or confusing the jury if Ms. Rodriguez introduced the exhibit into evidence substantially outweighs its probative value. Therefore, Miami-Dade County's motion to exclude ...


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