Illinois Appellate Court
Criminal Court
Motions in Limine
Grand jury indicted Defendant for endangering the life of a child. Court erred in granting Defendant’s motion to exclude evidence about Defendant’s substance-abuse history, treatment, prior use, and prescription. Although it would have violated Rule 404(b) of Illinois Rules of Evidence to allow State to introduce evidence that Defendant has a drug addiction to show propensity to commit charged offense, court’s unlimited grant of Defendant’s motion in limine broadly prohibited State from introducing relevant evidence about particular prescription drug, Defendant’s use of that drug, including a particular prescription, circumstances of offense, and state of mind. (APPLETON and STEIGMANN, concurring.)