Page:Echeverry v. Jazz Casino Co., LLC (20-30038) Opinion.pdf/15

 was not admitted on the issue of AWR’s negligence but to prove the Casino’s negligence in hiring AWR. Rule 411 was not violated.

The Casino also argues that the insurance evidence is irrelevant to its negligence because whether AWR had a certificate of insurance identifying its current policy at the time of hiring had no bearing on AWR’s safety or competence. The bar for relevant evidence is low; the evidence needs to have only “any tendency” to make a fact in question more or less likely. 401(a). A district court is given great deference in this determination. The district court did not abuse its discretion, and we do not need to reach the question of harmlessness.

C. The Casino’s internal policies

The Casino argues that the district court abused its discretion by admitting the Casino’s internal policies into evidence. The Casino relies on Dragna v. KLLM Transportation Services, L.L.C., 638 F. App’x 314, 319 (5th Cir. 2016), for this proposition. While Dragna (which is not precedent) held that internal policies did not establish the applicable standard of care, that panel did not go so far as to say that evidence that a principal violated its internal policies is irrelevant to the question of negligence. Id. at 320. We conclude that failure to follow internal policies can be relevant. The district court did not abuse its discretion by admitting the evidence.

D. Construction-site photographs

The district court granted the Casino’s motion in limine to exclude photographic evidence of construction sites because Echeverry was injured at a bird-removal site, not a construction site. At trial, though, the Casino’s expert witness was impeached with his deposition testimony that the bird-removal site where Echeverry was injured closely resembled a construction site. Because of that statement, the district court allowed the photographs of New Orleans construction sites to be introduced at trial.