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Bill Swan v. Interstate Brands Corporation

Citations: 333 F.3d 863; 2003 WL 21448405Docket: 02-2162

Court: Court of Appeals for the Eighth Circuit; August 20, 2003; Federal Appellate Court

Narrative Opinion Summary

Bill Swan appealed a jury verdict in favor of Interstate Brands Corporation (IBC) regarding his age discrimination claim after being demoted and terminated. Swan sought to admit a Severance Agreement into evidence to impeach an IBC witness concerning the timing of his termination decision. The district court excluded the Severance Agreement, determining it was not proper impeachment evidence and posed a risk of prejudice against IBC. The court concluded that the timing of the termination was not directly relevant to the age discrimination claim, and the Severance Agreement was inadmissible under Federal Rule of Evidence 408, which governs settlement discussions. The Eighth Circuit Court affirmed the district court's decision, stating that the exclusion did not constitute a clear abuse of discretion. The case highlights issues surrounding evidentiary rules and age discrimination claims in employment contexts.

Legal Issues Addressed

Admissibility of Evidence under Federal Rule of Evidence 408

Application: The court ruled that a Severance Agreement is inadmissible as evidence to impeach a witness when it relates to settlement discussions, as it poses a risk of prejudice and is not proper impeachment evidence.

Reasoning: The district court excluded the Severance Agreement, determining it was not proper impeachment evidence and posed a risk of prejudice against IBC.

Appellate Review of Evidentiary Exclusions

Application: The Eighth Circuit Court upheld the district court's exclusion of evidence, emphasizing that the decision did not constitute a clear abuse of discretion.

Reasoning: The Eighth Circuit Court affirmed the district court's decision, stating that the exclusion did not constitute a clear abuse of discretion.

Relevance of Evidence in Age Discrimination Cases

Application: The court found that evidence related to the timing of the termination decision was not directly relevant to the age discrimination claim and therefore excluded it.

Reasoning: The court concluded that the timing of the termination was not directly relevant to the age discrimination claim, and the Severance Agreement was inadmissible under Federal Rule of Evidence 408.