United States v. MILES, 1:19-cr-00183

Government filed a sealed motion in limine to exclude questioning about a 2004 disciplinary action involving a law-enforcement witness (LE Witness) in the criminal case against Arthur Miles (trial set March 7, 2022).
Miles is charged with possession with intent to distribute methamphetamine and cocaine, and two counts of being a felon in possession of a firearm.
In July 2004 LE Witness allegedly interfered with a street officer’s domestic-violence investigation (radioed officers to leave and make no report) and urged a prosecutor to release a suspect by claiming the suspect was his confidential informant; disciplinary board sustained violations and issued a written reprimand in October 2004.
Government argues the 2004 disciplinary action is marginally probative as to truthfulness, remote in time, and would be unfairly prejudicial or misleading; it notes similar exclusions by other judges in the district.
Court found the disciplinary matter’s probative value substantially outweighed by risk of unfair prejudice, confusion, and jury misdirection given the minor sanction and the passage of time, and granted the Government’s motion.
The order bars Miles’ counsel from referencing or introducing the 2004 disciplinary action; the motion remains sealed and the court emphasized the ruling is preliminary and may be revisited at trial if circumstances change.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of 2004 disciplinary action for impeachment	Evidence is marginally probative of truthfulness, remote in time, and unfairly prejudicial; should be excluded	No opposing brief filed; court presumes no opposition	Excluded: probative value substantially outweighed by unfair prejudice, misleading jury, and confusion; written reprimand and passage of time reduce relevancy
Pretrial ruling on admissibility (motion in limine standard and finality)	Seeks a preliminary district-wide ruling to avoid inconsistent outcomes	No response; no asserted counterargument	Granted but preliminary: in limine order may be revisited at trial; defendant may seek a hearing if evidence becomes relevant

Jenkins v. Chrysler Motors Corp., 316 F.3d 663 (7th Cir. 2002) (district courts have broad discretion on evidentiary questions and motions in limine)
Hawthorne Partners v. AT&T Technologies, Inc., 831 F. Supp. 1398 (N.D. Ill. 1993) (motions in limine ordinarily deferred until trial unless evidence is clearly inadmissible)
Luce v. United States, 469 U.S. 38 (1984) (in limine rulings are preliminary and may be revisited when testimony unfolds at trial)
Thompson v. City of Chicago, 722 F.3d 963 (7th Cir. 2013) (relevant evidence may be excluded if probative value is substantially outweighed by danger of unfair prejudice or jury confusion)
Wilson v. Williams, 182 F.3d 562 (7th Cir. 1999) (trial judge may make tentative or conditional rulings requiring parties to renew issues at trial)