Filed: Aug. 29, 2016
Latest Update: Aug. 29, 2016
Summary: MEMORANDUM AND ORDER STACI M. YANDLE , District Judge . On July 20, 2016, the Court held a Final Pretrial Conference in this matter and issued rulings on the parties' motions in limine. (Docs. 181, 186). Now before the Court is Defendant's Motion to Reconsider two of the Court's rulings. Plaintiff's second motion in limine sought to exclude all evidence of Plaintiff's grievances and prior complaints. Defendant, however, argued that a grievance dated July 24, 2011, is relevant and thus
Summary: MEMORANDUM AND ORDER STACI M. YANDLE , District Judge . On July 20, 2016, the Court held a Final Pretrial Conference in this matter and issued rulings on the parties' motions in limine. (Docs. 181, 186). Now before the Court is Defendant's Motion to Reconsider two of the Court's rulings. Plaintiff's second motion in limine sought to exclude all evidence of Plaintiff's grievances and prior complaints. Defendant, however, argued that a grievance dated July 24, 2011, is relevant and thus ..
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MEMORANDUM AND ORDER
STACI M. YANDLE, District Judge.
On July 20, 2016, the Court held a Final Pretrial Conference in this matter and issued rulings on the parties' motions in limine. (Docs. 181, 186). Now before the Court is Defendant's Motion to Reconsider two of the Court's rulings.
Plaintiff's second motion in limine sought to exclude all evidence of Plaintiff's grievances and prior complaints. Defendant, however, argued that a grievance dated July 24, 2011, is relevant and thus admissible. The Court granted Plaintiff's motion over Defendant's objection. Plaintiff also objected to the Defendant introducing Plaintiff's cumulative counseling summary as evidence, asserting that the document is not relevant. See Docs. 160, 168. The Court ruled that the cumulative counseling summary is inadmissible over Defendant's objection. Defendant now moves the Court for reconsideration of those rulings.1
DISCUSSION
The purpose of a motion in limine is to allow the trial court to rule on the relevance and admissibility of evidence before it is offered at trial. See Luce v. United States, 469 U.S. 38, 41, n.4 (1984) ("[A]lthough the Federal Rules of Evidence do not explicitly authorize in limine rulings, the practice has developed pursuant to the district court's inherent authority to manage the course of trials."). It serves to "aid the trial process by enabling the court to rule in advance of trial on the relevance of certain forecasted evidence, as to issues that are definitely set for trial, without lengthy argument at, or interruption of, the trial." Wilson v. Williams, 182 F.3d 562, 566 (7th Cir. 1999) (citing Palmieri v. Defaria, 88 F.3d 136, 141 (2d Cir. 1996)).
Motions in limine also may save the parties time, effort, and cost in preparing and presenting their cases. Pivot Point Intern., Inc. v. Charlene Products, Inc., 932 F.Supp. 220, 222 (N.D. Ill. 1996). A court may reserve judgment until trial, so that the motion in limine is placed "in an appropriate factual context." Nat'l Union Fire Ins. Co. of Pittsburgh v. L.E. Myers Co. Group, 937 F.Supp. 276, 287 (S.D.N.Y. 1996). Stated another way, rulings in limine are "subject to change when the case unfolds" at trial. Luce, 469 U.S. at 41. Moreover, the court may alter a ruling in limine based on developments at trial or sound judicial discretion. Luce, 469 U.S. at 41.
In requesting reconsideration, Defendant Hartman offers no additional information or arguments which persuade the Court that either the July 24, 2011 grievance or the cumulative counseling summary is relevant or material. Accordingly, Defendant's motion is DENIED. However, this denial is without prejudice; Defendant may tender an offer of proof at trial for the admission of these documents.
IT IS SO ORDERED.
