SIGO v. Prudential Property and Cas. Ins. Co., 946 N.E.2d 1248

Sigo sued Prudential for fire loss on his insured home; Prudential alleged Sigo caused the fire and refused payment.
Concurrently, Sigo was charged with arson and acquitted by a criminal jury.
Prudential moved in limine to exclude any reference to Sigo's criminal trial and acquittal from the civil breach-of-contract trial.
Trial court granted the motion; the order was certified for interlocutory appeal.
Issue on appeal: whether the court abused its discretion in balancing probative value of the acquittal against potential unfair prejudice under Rule 403.
Court affirmed, holding the acquittal evidence had marginal probative value and substantial risk of unfair prejudice to Prudential.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of acquittal evidence abused discretion?	Sigo argues acquittal is relevant to witness bias and context; door opened by Prudential's strategy.	Acquittal is not admissible to prove innocence and risks unfair prejudice; burden differs between criminal and civil cases.	No abuse; probative value marginal, prejudice substantial; exclusion affirmed.

Hawkins v. Auto-Owners (Mut.) Ins. Co., 608 N.E.2d 1358 (Ind. 1993) (felony conviction admissible, not conclusive in civil actions)
Kimberlin v. DeLong, 637 N.E.2d 121 (Ind. 1994) (convictions admissible; acquittals not automatically admissible)
Lepucki v. Lake County Sheriff's Dep't, 801 N.E.2d 636 (Ind.Ct.App. 2003) (admission of certain criminal records in tort cases can be reversible error)
McSweeney v. Utica Fire Ins. Co. of Oneida County, 224 F.2d 327 (4th Cir. 1955) (acquittal evidence generally not admissible in civil fire-insurance actions)
Greenberg v. Aetna Ins. Co., 427 Pa. 511, 235 A.2d 576 (Pa. 1967) (acquittal evidence inadmissible in civil fire-insurance actions)
Dickey v. Tennessee Odin Ins. Co., 190 Tenn. 96, 228 S.W.2d 73 (1950) (acquittal evidence generally inadmissible in insurance actions)