Illinois Appellate Court
Civil Court
Motions in Limine
At five-day trial for injuries sustained in car accident, court properly granted Platntiff's motion in limine barring Defendants from mentioning Plaintiff's prior low back injuries and treatment and subsequent fracture in her low back after unknown injury. Plaintiff's injuries were not such that a layperson could readily appraise the relationship between injuries located in low back and injuries to coccyx, piriformis muscle, and sacroiliac joint. Thus, exception of Voykin v. DeBoer is inapplicable, so that evidence of injuries to other parts of Plaintiff's body are inadmissible absent medical or other competent evidence establishing causal connection between other medical conditions and injuries sustained in accident.
(STEWART and CATES, concurring.)