Spies v. Amine

Illinois Appellate Court
Civil Court
Motion in Limine
Citation
Case Number: 
2026 IL App (1st) 251630
Decision Date: 
Friday, September 18, 2026
District: 
1st Dist.
Division/County: 
5th Div./Cook Co.
Holding: 
Affirmed in part, reversed in part.
Justice: 
WILSON

Plaintiff appealed from judgment entered for the defendants in a medical malpractice case, which was entered by the trial court after it barred plaintiffs’ retained medical expert from offering opinions on proximate causation and damages for failure to disclose under SCR 213. The appellate court affirmed in part and reversed in part, finding that while the trial court did not abuse its discretion in barring the undisclosed causation testimony, it was improper to enter a dispositive judgment based on a motion in limine. The appellate court noted that the circuit court could, on remand, permit the filing of a formal dispositive motion or proceed directly to trial. (ODEN JOHNSON, concurring and MITCHELL, concurring in part and dissenting in part)