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Evidence in Arizona Fatal Prisoner Abuse Suit Tailored in In Limine Ruling

The U.S. District Court for the District of Arizona ruled in limine on pre trial evidence following the denial of qualified immunity for Maricopa County Sheriff Joseph Arpaio in a § 1983 suit involving the death of Tent City prisoner Phillip Wilson, who was fatally beaten by other prisoners.

Evidence regarding a previous prisoner's fatal beating was allowed by the court, but only as to the defendants’ liability for occurrences in Tent City. An Amnesty International article and Department of Justice press release were allowed, with instructions to be mindful of hearsay. Other hearsay testimony was permitted pending the court’s approval for relevancy.

The district court held that F.R.C.P. Rule 30 precluded audio/videotaped psychiatric exams from being introduced. Some prior negative personal and family history involving Wilson’s family was allowed, but the court ordered the exclusion of references to his mother's rape, abusive first marriage and stillborn daughter. Wilson's prior drug use and alleged suicidal tendencies were reserved for the court’s determination at trial. Medical lien limit requests were denied.

Testimony regarding six prisoners' alleged involvement in Wilson's beating was allowed. A guard's testimony as to crime scene evidence was permitted, excluding his non expert "blood coagulation" findings. Articles concerning Sheriff Arpaio and Maricopa County Jails were allowed on an article to article basis, as were television and videotape footage. Autopsy photos were allowed. No references were permitted regarding the fact that Wilson's assailants had not been prosecuted. See: Wilson v. Maricopa County, U.S.D.C. (D. Ariz.), March 2, 2007); 2007 WL 686726.

This case went to trial in April 2007, resulting in a jury verdict in favor of the defendants. Wilson’s estate filed a motion for a new trial, claiming the verdict was “against the clear weight of the evidence” and raising claims of inadequate jury instructions. The district court denied the motion in a lengthy ruling on July 5, 2007. See: Wilson v. Maricopa County, U.S.D.C. (D. Ariz.), (July 5, 2007); 2007 WL 1992091.

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Related legal cases

Wilson v. Maricopa County

Wilson v. Maricopa County