Reyes V. Missouri Pac. R. Co. Case Study

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Lord In Reyes v. Missouri Pac. R. CO., the appellant, Joel Reyes, sought rehabilitation from the defendant, Missouri Pacific Railroad Company, after being run over by one of the defendants trains while lying on the tracks. The appellant claims the defendant was negligent due to its inability to see the plaintiff in time to stop the train. The defendant refutes the plaintiffs claim by blaming the plaintiff for contributory negligence because the plaintiff was believed to be drunk on the night in question based off of pass arrest records . In a motion in limine Reyes ask for the exclusion of the evidence presented by the defense. The trial court, however denied the plaintiff’s request and ruled in favor of the defendant. The plaintiff, Reyes, …show more content…

Reyes v. Missouri Pac. R. Co., 589 F.2d 791, 794 (5th Cir. 1979) The appellant court held that it was not. According to rule 404 under the Federal Rules of Evidence, “evidence of a person 's character or character trait is not admissible to prove that on a particular occasion the person acted in accordance with the character or trait”. Fed. R. Evid. 404 Under this rule the evidence of Reyes prior convictions admitted by the trial court, “purpose of showing that he was intoxicated on the night that he was run over by defendant-appellee 's train” proves to be inadmissible under Rule 404(a) of the Federal Rules of Evidence. Reyes v. Missouri Pac. R. Co., 589 F.2d 791, 792 (5th Cir. 1979) The courts due mention the exceptions on the admission of character evidence. However the court did not use the evidence of Reyes past drunkenness to prove some other criminal purpose. Since the trial court failed to do the latter, and instead entered evidence on the basis of character to prove that the plaintiff acted in accordance with his character trait during the night in question, it went against the modern rules set out in FRE 404 and is therefore …show more content…

In their conclusion the Appellate court reasoned that the argument of Reyes drunkenness by the defense as a form of habit carried little weight. They agree that there is no exact formula for establishing habit. However they do hold it to a standard of “uniformity of response”. Meaning the defendant needed to prove in order to result to habit evidence that “intoxication on a given occasion depends on the degree of regularity of the practice and its coincidence with the occasion”. Reyes v. Missouri Pac. R. Co., 589 F.2d 791, 795 (5th Cir. 1979) They concluded that four instances over a period of approximately four years could not constitute as or satisfy the requirements for establishing

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