Walker v. White, No. 17-1345 (8th Cir. 2018)
Annotate this CasePlaintiff, an inmate at a correctional center, filed suit against two officers under 42 U.S.C. 1983 for failure to protect in violation of the Eighth Amendment. The jury found for the officers and plaintiff appealed. The court assumed without deciding that plaintiff's offer of proof sufficiently preserved the issue of whether the district court should have allowed cross-examination a corrections guard about a disciplinary report about the guard. The court held that the district court did not abuse its discretion in refusing to permit the cross-examination because the probative value of the evidence was low, and the danger of unfair prejudice and a "mini-trial" was great. The court also held that the district court did not plainly err in admitting evidence of the second incident, which was less probative than the first and similarly risked unfair prejudice and confusion of the issues. Finally, the district court did not abuse its discretion in admitting testimony about plaintiff's aggressive behavior toward cellmates where any error was harmless.
Court Description: Benton, Author, with Colloton and Erickson, Circuit Judges] Prisoner case - Prisoner civil rights. Action by an inmate on claims defendants failed to protect him from sexual assault by his cellmate. Assuming, without deciding, that plaintiff's offer of proof was sufficient to preserve the question of whether the district court erred in refusing to permit him to cross-examine a corrections guard about a disciplinary report against him, the district court did not abuse its discretion in refusing to permit the cross-examination as the probative value of the evidence was low, and the danger of unfair prejudice and a "mini-trial" was great; second incident on which the plaintiff wished to cross-examine the witness had even less probative value and the court did not plainly err in preventing the questioning as the testimony risked similar unfair prejudice and confusion; admission of testimony that plaintiff had a history of being aggressive with his former cellmates was harmless.
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