## Facts

- In 1979, Ramon Magayanes was arrested in Chicago for disorderly conduct by police officers employed by the City of Chicago.
- Magayanes was placed in a “squadrol” vehicle (a police transport vehicle) to be taken to a police station.
- When the squadrol arrived at the station, officers found Magayanes on the floor of the vehicle with blood around his nose and lips.
- The officers took Magayanes to a hospital, where he became more belligerent and refused treatment.
- Magayanes later sued the City of Chicago and the involved officers under 42 U.S.C. §§ 1983 and 1985, alleging constitutional violations arising from the arrest and transport, including a claim that the City used a defectively designed squadrol vehicle.
- Before trial, Magayanes sought to introduce testimony from Franklin, a witness who claimed that in 1980 he was arrested by Chicago police, severely beaten, placed in a squadrol, and shackled to the vehicle.
- The district court granted a motion in limine excluding Franklin’s testimony, concluding it was not sufficiently connected to Magayanes’s incident and that it would create unfair prejudice and distract the jury.
- The case was tried to a jury, which returned a verdict for the defendants. Magayanes appealed, challenging (among other rulings) the exclusion of Franklin’s testimony.

## Issues

1. Did the district court abuse its discretion by excluding Franklin’s “other incident” testimony as irrelevant or, in any event, as unfairly prejudicial under the Federal Rules of Evidence?
2. Was the jury’s defense verdict on Magayanes’s § 1983 and § 1985 theories unsupported by the evidence or infected by reversible trial error?

## Decision

- The Seventh Circuit affirmed the judgment for the defendants.
- The court held the district court acted within its discretion in excluding Franklin’s testimony because the later incident involved different circumstances and officers, and any limited value was outweighed by the risk of unfair prejudice, confusion, and a trial within a trial.
- The court found no basis to overturn the jury’s verdict on the remaining challenges, concluding the record permitted the jury to reject Magayanes’s claims about the arrest, use of force, and the City’s alleged liability tied to the squadrol.

## Legal Principles

- Trial courts have broad authority over evidentiary rulings; appellate review is for abuse of discretion, and reversal requires a showing that the ruling likely affected the trial’s fairness.
- Evidence of a different alleged incident involving police misconduct may be excluded when it is too remote or dissimilar to the events at issue and would likely mislead the jury or cause unfair prejudice. Fed. R. Evid. 401, 403.
- In § 1983 false-arrest litigation, the existence of probable cause (or at least a reasonable good-faith belief in the legality of the arrest) defeats liability for the arresting officers.
- Municipal liability under § 1983 cannot rest on respondeat superior; a plaintiff must connect the asserted constitutional injury to a municipal policy, practice, or decision, and must show causation between that municipal action and the alleged deprivation.

## Conclusion

The Seventh Circuit upheld the defense verdict, holding that the district court reasonably excluded a witness’s account of a separate, later squadrol incident as minimally helpful and substantially prejudicial, and that the jury’s rejection of Magayanes’s § 1983 and § 1985 claims—arising from his arrest, transport, and the City’s alleged squadrol-related liability—was supported by the trial record.


Magayanes v. Terrance, 739 F.2d 1131 (1983)