People v. Price

Defendant was convicted, after jury trial, of 1st degree murder and was sentenced to 60 years. Court did not err in denying Defendant's motion in limine to exclude testimony from paramedic that victim's body displayed signs of rigor mortis when he examined it at the scene, arguing that he was not an expert. Paramedic's statement that body was suffering from "obvious" rigor mortis could be considered a lay opinion. Trial court has discretion to determine what fact, if any, is being asserted by implication through a statement. Court did not abuse its discretion by overruling Defendant's hearsay objection to witness's statements in text messages. Rulings on motions in limine are always subject to reconsideration during trial, and trial courts have discretion to reexamine their prior rulings on motions in limine when full context of evidence at issue becomes more clear at trial. State permissibly argued reasonable inferences to be drawn from evidence presented as to time of death. (CAVANAGH and HARRIS, concurring.)