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Hill v. City of Chicago et al

July 6, 2011

HILL
v.
CITY OF CHICAGO ET AL



Name of Assigned Judge Sitting Judge if Other or Magistrate Judge Amy J. St. Eve than Assigned Judge

CASE TITLE

DOCKET ENTRY TEXT

The Court grants Plaintiff's motion in limine no. 6 [484].

O[ For further details see text below.] Notices mailed by Judicial staff.

STATEMENT

Before the Court is Plaintiff Harold Hill's motion in limine no. 6, in which he seeks to bar Defendants from admitting crime scene photographs pursuant to Federal Rules of Evidence 401, 403. For the following reasons, the Court in its discretion, grants Plaintiff's motion in limine no. 6. See Fox v. Hayes, 600 F.3d 819, 839 (7th Cir. 2010) (district courts are afforded special deference when determining if evidence is unduly prejudicial); see also United States v. Thomas, 321 F.3d 627, 630 (7th Cir. 2003) (stating "[t]he balancing of probative value and prejudice is a highly discretionary assignment.").

BACKGROUND

On October 14, 1990, Kathy Morgan was killed and left in an abandoned building in Chicago, Illinois. The building and Morgan's body were set on fire in an apparent attempt to hide the crime. On March 20, 1992, Chicago Police Officers arrested Hill for possession of a stolen automobile and possession of a handgun. After being transported to the Seventh District Police Station at 61st Street and Racine Avenue, Hill admitted to committing two armed-robberies.

During the follow-up investigation of the armed robberies, Chicago Detectives Boudreau and Halloran asked Hill about other crimes, and Hill indicated that he had knowledge of the Morgan homicide. Twenty-six hours after Hill's arrest, Hill gave a court-reported statement implicating himself and two other men, Dan Young and Peter Williams, in the Morgan crimes. Hill alleges that Detectives Boudreau and Halloran, along with Assistant State's Attorney Rogers, coerced his confession.

Courtroom Deputy KF Initials:

Hill's criminal case commenced on March 22, 1992 with a probable cause to detain and bond hearing in the Circuit Court of Cook County. On April 13, 1992, Hill was indicted for the murder and sexual assault of Morgan. In September 1994, Hill and his co-defendant Dan Young were tried simultaneously -- but to separate juries -- for Morgan's sexual assault and homicide. The State introduced Hill's confession as evidence against him during his trial. In addition, both Hill and Young testified at trial maintaining their innocence and asserting that law enforcement coerced them into giving their confessions. In September 1994, the juries convicted Hill and Young for Morgan's sexual assault and homicide. Over a decade later, the results of DNA testing resulted in the trial court vacating Hill's conviction and the State dropping the charges against Hill.

On January 30, 2007, Hill filed an eleven-count Amended Complaint against the City of Chicago and present and former Chicago Polices Officers in the Violent Crimes Division at Area 3, as well as a Cook County Assistant State's Attorney. At this stage of the litigation, the following counts remain: (1) Hill's Fifth Amendment coerced confession claim; (2) his Section 1983 conspiracy claim based on his coerced confession claim; and (3) his failure to intervene claim based on his coerced confession.

LEGAL STANDARD

Trial courts have broad discretion when ruling on evidentiary issues prior to trial. See Jenkins v. Chrysler Motors Corp., 316 F. 3d 663, 664 (7th Cir. 2002); United States v. Lillie, 669 F. Supp. 2d 903, 905 (N.D. Ill. 2009). While the "Federal Rules of Evidence do not explicitly authorize in limine rulings, the practice has developed pursuant to the district court's inherent authority to manage the course of trials." Luce v. United States, 469 U.S. 38, 41 n.4 (1984). The Seventh Circuit has repeatedly recognized the importance of motions in limine by noting that motions in limine help to avoid delays in litigation. See generally Wilson v. Williams, 182 F.3d 562, 566 (7th Cir. 1999); see also Jonasson v. Lutheran Child & Family Servs., 115 F.3d 436, 440 (7th Cir. 1997) (stating "[t]he prudent use of the in limine motion sharpens the focus of later trial proceedings and permits the parties to focus their preparation on those matters that will be considered by the jury."). Essentially, ...


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