## Facts

- Juan Andrade sued Walgreens-related entities for negligence and corporate negligence after he was pricked by a used angiocath needle allegedly discarded improperly.
- Before trial, Andrade moved in limine to exclude (1) evidence of his immigration status and (2) evidence concerning his employment records.
- Andrade’s counsel represented that Andrade would testify at trial, making his credibility subject to impeachment.
- Walgreens sought to use Andrade’s immigration status to impeach his credibility.
- Andrade argued immigration-status evidence would create unfair prejudice and should be excluded under Federal Rule of Evidence 403.

## Issues

1. Whether Andrade’s immigration status could be introduced to impeach his credibility, or whether it should be excluded under Federal Rule of Evidence 403 due to unfair prejudice substantially outweighing probative value.
2. Whether, and to what extent, employment-record evidence should be excluded under the Federal Rules of Evidence, including Rule 403.

## Decision

- The court granted Andrade’s motion in limine in part and denied it in part.
- The court substantially restricted introduction of immigration-status evidence, finding its impeachment value minimal and its risk of unfair prejudice substantial.
- The court permitted employment-record evidence only to the extent it was directly relevant (including to damages), and excluded employment-related material where Rule 403 concerns predominated.

## Legal Principles

- Under Federal Rule of Evidence 607, once a party testifies, the party’s credibility may be attacked like any other witness.
- Under Federal Rule of Evidence 403, relevant evidence may be excluded if its probative value is substantially outweighed by dangers such as unfair prejudice, confusion, or misleading the jury.
- Immigration status is generally of limited probative value on credibility in a negligence trial and presents a high risk that jurors will draw improper character inferences; courts therefore often exclude or sharply limit such evidence under Rule 403 when not tied to liability or damages.
- Employment records may be admitted when they bear directly on contested issues (including damages), but may be excluded when they invite collateral disputes or other Rule 403 harms.

## Conclusion

In this pretrial evidentiary ruling, the court applied Rules 607 and 403 to hold that immigration-status evidence could not be used merely as a credibility attack because unfair prejudice substantially outweighed any marginal probative value, while employment-record evidence was admissible only within tightly limited, directly relevant bounds.


Andrade v. Walgreens-OptionCare, Inc., 784 F. Supp. 2d 533 (E.D. Pa. 2011)