Illinois Appellate Court
Criminal Court
Motions in Limine
Defendant was convicted of aggravated battery. State presented circumstantial evidence that Defendant was responsible for setting a fire which occurred at the victim's home shortly after the battery incident. Evidence was properly admissible other-crimes evidence for the purpose of either describing the chain of events that occurred around the same time as, and at the same location as, the charged crime (the "continuing narrative" exception), or demonstrating that Defendant attempted to destroy evidence as an expression of his consciousness of guilt. Reversal not warranted by court having given limiting instruction after closing arguments rather than at the time the other-crimes evidence was presented. (KNECHT and McCULLOUGH, concurring.)