Case Law Update: Motions in Limine in Automobile Accident

Ford v. Grizzle, No. 5-08-185 (2-17-10) involved a Suit filed for injuries sustained in rear-end car accident; jury verdict for Defendant. Court properly allowed evidence of Plaintiff’s three prior car accidents and back and neck injuries, including one accident for which he continued to treat following accident in question; and photographs of Plaintiff’s vehicle, which showed no damage. Vehicle photos could help jury to assess relationship between vehicle damage and injuries, without aid of expert. Not error to allow Defendant’s closing argument remarks that Plaintiff initially sought medical bills for all three accidents, but was asking jury for only those bills related to accident in question; remarks did not infer settlement negotiations or offers. This Illinois case will have an impact on automobile accident law.

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