“The primary purpose of a motion in limine is to preclude reference to potentially prejudicial evidence prior to the trial court's definitive ruling on its admissibility.” (See State v. Jensen (2007) 741 N.W.2d 823; State v. Davis (1976) 240 N.W.2d 662, 663.)
“Generally, any error based on the trial court's disposition of a motion in limine is not preserved unless the record includes a timely objection when the challenged evidence is offered at trial.” (See id.)
“The resolution of a preservation of error issue is not controlled by the title of the motion or its prayer." (See State v. Jensen (2007) 741 N.W.2d 823; State v. O'Connell (1979) 275 N.W.2d 197, 202.)
“Our concern is what the ruling of the trial court does or purports to do." (See id.)
“A ruling limited to protection from prejudicial references must be distinguished from a ruling on the admissibility of the challenged evidence.” (State v. Jensen (2007) 741 N.W.2d 823; State v. Miller (1975) 229 N.W.2d 762, 768.)
“If the trial court's ruling is dispositive on the issue of admissibility, it is considered final for purposes of appeal and no further objection is necessary.” (See id.)
Rule 2.11 of the Iowa Rules of Criminal Procedure governs motions in limine.
“Any defense, objection, or request that is capable of determination before trial may be raised prior to trial by motion.” (See Iowa R. Crim. P. 2.11.)
“The following must be raised prior to trial…(g) Motions in Limine…” (See id.)
“We review the court's evidentiary rulings for an abuse of discretion.” (See Knowlton v. Grinnell Select Ins. Co. (2016) 880 N.W.2d 518; Hall v. Jennie Edmundson Mem'l Hosp. (2012) 812 N.W.2d 681, 685.)
“A district court abuses its discretion when its decision rests on grounds or on reasons clearly untenable or to an extent clearly unreasonable.” (See id.)
“There will be no abuse of discretion found unless a party has suffered prejudice.” (See id.)
“The district court is given broad discretion in evidentiary matters, and we will disturb its rulings upon a showing of abuse.” (See id.)
It is well settled that "the motion in limine is not ordinarily employed to choke off an entire claim or defense. Rather, it is usually used to prohibit mention of some specific matter, such as an inflammatory piece of evidence, until the admissibility of that matter has been shown out of the hearing of the jury.” (See Hauan Farms v. Northland Coop., No. 1-332 / 00-0370, at *1 (Iowa Ct. App. Dec. 12, 2001); Lewis v. Buena Vista Mut. Ins. Ass'n (1971) 183 N.W.2d 198, 200-01.)
It is also well settled that “a ruling sustaining a motion in limine is generally not an evidentiary ruling. Rather, a ruling sustaining a motion in limine simply adds a procedural step to the introduction of allegedly objectionable evidence.” (See Dubuque Injection Serv. Co. v. Kress, No. 16-0399, at *8 (Iowa Ct. App. June 21, 2017); Twyford v. Weber (1974) 220 N.W.2d 919, 923; Johnson v. Interstate Power Co. (1992) 481 N.W.2d 310, 317 [recognizing a ruling sustaining a motion in limine merely adds a procedural step to the offer of evidence and that if the evidence is not offered, there is nothing preserved to review on appeal].)
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