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How Not to File a Motion in Limine in a Florida Criminal Case

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A good Orlando defense attorney understands the strategic uses of motions in limine. When used correctly, these motions can protect clients from having to endure evidence that will unfairly inflame the emotions of the jury against them. A motion in limine seeks to exclude prejudicial evidence, thereby allowing the jury to form decisions based on impartial facts and evidence. Motions in limine may also be used to obtain an advance ruling on the admissibility of evidence.

As a Florida criminal defense lawyer, I can also tell you that there are right ways and wrong ways to file these motions. They should be filed selectively and reasonably. Too many generic motions will likely frustrate the judge, which could lead the court to discredit the motions.

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Incorrect Uses of Motions in Limine from an Orlando Defense Attorney

What the motion in limine is not – or, at least, should not be – is a blanket defense for a client. Many trial attorneys want to use this motion as a generic refusal of a particular kind of evidence or to prevent opposing counsel from introducing evidence that they would never allow in the first place. For example, attorneys may write motions to exclude items that are already excluded by the Evidence Code.

These kinds of motions in limine often take an excessive amount of time to write and almost as long to read, which slows down the trial and makes no one happy – particularly the judge. Worse, if the motion is too general, you can actually call attention to the very issue that you are trying to prevent from being entered into evidence.

Another mistake is drafting a motion that is merely a backhanded motion to dismiss or call for summary judgment. This is an abuse that is severely frowned upon, and will likely cause your motion to be denied.

In order for motions in limine to work the way they are intended, a motion must focus on specific evidentiary issues and seek to strike objectionable evidence that may be highly prejudicial. For example, you do not want unreasonably shocking photos of an accident scene allowed into evidence. Other prejudicial evidence might include a defendant’s prior arrests or unrelated criminal offenses, or allowing the prosecutor to refer to the defendant as the “accused” or other undermining terms.

Learn more about how trials work and when motions in limine can best be used in your case.

Your future may depend on the criminal defense lawyer you choose. Do not wait for the court to appoint an attorney to represent you. If you are facing criminal charges in the Orlando area, contact our defense attorneys or call 855-Kramer-Now (855-572-6376) for a free initial consultation.

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