United States v. Kent L. Buckner

ILANA DIAMOND ROVNER, Circuit

Judge, concurring.

I fully agree that the district court abused its discretion by excluding all of the proffered evidence without reviewing the tape recordings. I write separately only to offer a brief defense of motions in limine, for I do not view such motions in the same fight as do my colleagues. In my experience, motions in limine serve a very useful purpose in streamlining trials by settling evidentiary disputes in advance, rather than allowing trials to be interrupted in mid-course for the consideration of potentially lengthy and complex evi-dentiary issues. I also believe that, where possible, such motions should be resolved in advance of trial so as to eliminate the prospect of confrontations over the admission of evidence occurring in the jury’s presence. I recognize, of course, that it may sometimes be prudent to reserve ruling until the evidence relevant to the motion has been offered at trial. That is a judgment call for the district court to make.

I also agree that judges are busy on the morning of trial and that a motion in limine made for the first time at that point is not entirely welcome. This motion, however, was filed ten days in advance of trial, and the district judge gave no indication that the timing of the motion prevented the court from giving it due consideration. Indeed, I am confident that district judges are well-equipped to issue appropriate scheduling orders to insure that they have sufficient time to rule on pretrial motions. I therefore see no need for the majority to comment on the proper handling of motions in limine that are presented to the judge so close to the first day of trial as to wreak havoc with the court’s schedule. That simply did not occur in this case.