## Facts

- Reginald Carter, a Pennsylvania state inmate, filed a 42 U.S.C. § 1983 action alleging that three correctional officers used excessive force during a cell search on September 22, 1977, and that the superintendent was liable in a supervisory capacity.
- Carter claimed the officers ordered him out of his cell and beat him with batons, flashlights, fists, and feet, including multiple blows to the head and many baton strikes.
- Three nearby inmates testified they heard a beating but had limited visibility; two reported observing no bruises afterward, and one noticed facial swelling.
- The officers denied beating Carter, contending Carter grabbed a baton and only necessary force was used to subdue him.
- At an evidentiary hearing, the defense introduced a letter authored by Carter describing how inmates could file brutality complaints in a way likely to succeed; the trial factfinder treated the letter as suggesting a method for making false complaints to obtain institutional benefits.
- Carter admitted writing the letter but objected to its admission as irrelevant and improper under the Federal Rules of Evidence.

## Issues

1. Whether Carter’s letter was relevant and admissible, or instead improper character/credibility evidence barred by Federal Rules of Evidence 401, 404(b), and 608.
2. Whether the letter’s probative value was substantially outweighed by unfair prejudice under Federal Rule of Evidence 403.
3. Whether the magistrate’s prison-based evidentiary hearing functioned as an improper summary-judgment substitute rather than a trial on the merits.

## Decision

- The Third Circuit affirmed judgment for the defendants.
- The court held the letter was properly admitted because it bore on a central disputed matter—credibility—and on the plausibility of Carter’s brutality allegation.
- The court found no abuse of discretion under Rule 403, emphasizing the reduced risk of unfair prejudice in a bench trial.
- The court held the magistrate’s proceeding was a trial on the merits: live testimony was taken, witnesses were cross-examined, and credibility findings were made and adopted by the district court.
- The court left undisturbed the factfinding that no beating occurred, applying deferential review to the trial-level credibility determinations.

## Legal Principles

- Evidence is relevant if it tends to make a consequential fact more or less probable; in a case turning on credibility, material bearing on a party’s motive or method for making the disputed claim can satisfy Rule 401.
- Rule 404(b) does not bar evidence offered for a non-propensity purpose (such as motive, plan, or method) closely connected to a disputed issue, even if it also reflects negatively on the proponent’s character.
- Rule 608 limits certain attacks on a witness’s character for truthfulness, but does not exclude evidence independently relevant to issues beyond generalized character impeachment.
- Under Rule 403, trial courts have broad discretion to admit probative evidence, and concerns about unfair prejudice are diminished when the factfinder is a judge rather than a jury.
- A magistrate-conducted evidentiary hearing with live testimony, cross-examination, and credibility determinations—later adopted by the district court—may constitute a final merits adjudication rather than summary judgment.

## Conclusion

The Third Circuit held that an inmate’s letter describing tactics for pursuing brutality complaints was admissible where it was probative of credibility and the likelihood of fabrication, and it upheld a magistrate’s prison-based evidentiary hearing as a full bench trial supporting final judgment for the defendants.


Carter v. Hewitt, 617 F.2d 961 (3d Cir. 1980)