Article: Although a trial court's failure to rule on a motion in limine may constitute an abuse of discretion, a harmless error will not overturn a ruling.(Illinois)

People v Holloway, No. 1-05-3439; 2009 WL 2259100 (1st D 2009)

On July 24, 2009, the Illinois Appellate Court, First District, affirmed the judgment of the Circuit Court of Cook County, holding that the trial court did not err when it deferred ruling on the defendant's motion in limine until after he testified. The defendant's conviction stemmed from a car break-in that occurred in July 2004. Prior to the trial, the defendant filed a motion in limine to bar the state from admitting evidence of his three prior drug-related convictions. Subsequently, the trial court deferred its ruling on the motion until after the defendant testified. After his conviction, the ...

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