When a trial date approaches, litigators have their own checklists to keep track of pretrial preparations. As they go through the checklist, they may feel a little like a baseball manager filling out a lineup card. They should always find a spot in the lineup for the motion in limine, a versatile, utility infielder on whom you can rely to keep unhelpful information from reaching a jury’s attention.
The most common purpose of a motion in limine is to prevent the admission into evidence of testimony or documents that may damage a party’s case, but that also may suffer from some evidentiary shortcoming. It is, as the 7th Circuit once has noted, “a request for guidance by the court regarding an evidentiary question.”