00-1892 Mathis v. Phillips Chevrolet Inc.

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“According to an offer of proof Phillips made just before the trial began, there were significant irregularities in Mathis’ applications at these other dealerships. In one case, when the dealership offered Mathis an interview, Mathis left and never returned. In three other cases, the dealership alleged that Mathis filled out an application but took it home with him and never submitted it. In other cases Mathis lied on his applications. According to Phillips, although Mathis had worked as a car salesman for many years, his career had deteriorated in recent years. In the late 1980s and early 1990s, Mathis’s sales had diminished considerably, and he had become increasingly belligerent and even violent towards co-workers. His last several jobs had been short-lived, and none of his former employers was willing to act as a reference.

“In this case, the pattern of Mathis’ false applications to the other dealerships was very similar to what Phillips alleged occurred in this case, and the other applications and suits all occurred around the same time as Mathis’ application to and suit against Phillips.

“[T]o the extent the district court ruled that the evidence of Mathis’ prior lawsuits was not relevant to show anything other than a propensity to file baseless discrimination suits, we cannot agree with the district court’s assessment. Although evidence of Mathis’ other lawsuits could have been used for the forbidden purpose of suggesting that because Mathis had filed frivolous discrimination claims in the past, he was likely doing so again in this case, it could also have been used (with a proper limiting instruction) to show that Mathis was engaged in a plan or scheme to harass Chicago-area car dealerships, and that his methods or modus operandi in the prior suits were very similar to the approach he employed in this case.

“But the district court’s finding was not only that the relevance of the evidence was questionable, but also that any relevance the evidence had was outweighed by the prejudice the evidence would cause Mathis. The district court’s concern was a reasonable one. … Managers from the other dealerships would have testified that Mathis fabricated the prior claims, but Mathis disputed those allegations, and the district court was understandably reluctant to plunge into a series of mini-trials on the merits of each of the prior suits. Ultimately, the district court was faced with an offer of evidence that had some permissible uses but that could also have given rise to the impermissible inference that, because Mathis was given to filing frivolous lawsuits, the jury should not credit his claims in this suit. When ‘the same evidence has legitimate and forbidden uses, when the introduction is valuable yet dangerous,’ the district court has great discretion in determining whether to admit the evidence. United States v. Beasley, 809 F.2d 1273, 1278 (7th Cir. 1987). The district court acted within the scope of that discretion, and we will not disturb its judgment.”

Affirmed.

Appeal from the United States District Court for the Northern District of Illinois, Urbom, J., Wood, J.