State Court Motion in Limine - Missouri
MOTION IN LIMINE AND SUGGESTIONS IN SUPPORT
IN THE CIRCUIT COURT OF [COUNTY / CITY OF ST. LOUIS], MISSOURI
| Party | Role |
|---|---|
| [PLAINTIFF NAME] | Plaintiff |
| v. | |
| [DEFENDANT NAME] | Defendant |
Case No.: [________] Division: [________]
[PARTY NAME] moves for a ruling outside the jury's presence before [OPPOSING PARTY] refers to or offers the specific matter identified below. The requested ruling concerns [DESCRIBE EVIDENCE, ARGUMENT OR QUESTION WITH ENOUGH DETAIL TO IDENTIFY IT]. Trial is set for [DATE].
Matter and proposed use
- The anticipated matter is [IDENTIFY DOCUMENT, TESTIMONY, EXHIBIT, QUESTION OR ARGUMENT]. Its source and the basis to expect it at trial are [DEPOSITION PAGE / DISCLOSURE / EXHIBIT LIST / OTHER RECORD].
- The proponent's apparent purpose is [DESCRIBE THE INFERENCE OR ISSUE]. The motion concerns [IDENTIFY CLAIM, DEFENSE AND MATERIAL FACT].
- The Court should address this matter before it is mentioned to the jury because [CASE-SPECIFIC REASON A LATER OBJECTION WOULD BE INADEQUATE].
Ground for the requested ruling
Under Holdeman v. Stratman, No. WD80586 (Mo. Ct. App. Aug. 28, 2018), the Court evaluates both logical and legal relevance, weighing the matter's usefulness against the costs of unfair prejudice, confusion, delay, misleading the jury, waste of time, or needless cumulative proof. Here, [APPLY THAT FRAMEWORK TO THE IDENTIFIED MATTER, INCLUDING ANY PROPER USE AND A NARROWER ALTERNATIVE].
[IF EXPERT OPINION IS AT ISSUE: Identify whether this proceeding falls under § 490.065.1's listed family, juvenile, probate or no-right-to-jury categories; otherwise apply § 490.065.2. Identify the particular qualification, helpfulness, sufficient-data, reliable-method or application issue under the applicable subsection, and cite the opinion, disclosure and supporting record.]
[IF WITNESS COMPETENCY OR A LISTED COMMUNICATION BAR IS AT ISSUE: Identify the precise subdivision of § 491.060, the witness or communication involved, and the facts and exceptions that make it applicable.]
Movant requests [EXCLUSION / A LIMITING RULING / AN OFFER OF PROOF AND RULING BEFORE ANY MENTION TO THE JURY], limited to [DEFINE EXACT SCOPE]. Movant asks the Court to allow the proponent to approach the bench before attempting to use the matter for a purpose not resolved by the order.
Respectfully submitted,
____________________________
[ATTORNEY NAME], Mo. Bar No. [____]
[FIRM, IF ANY]
[MAILING ADDRESS]
Telephone: [____]
Facsimile, if any: [____]
Email, if any: [____]
Attorney for [PARTY NAME]
CERTIFICATE OF SERVICE
I certify that on [DATE] I served this Motion and attachments on [NAME OF EACH PERSON SERVED] by [RULE 43.01 METHOD] at [ADDRESS USED FOR EACH PERSON].
____________________________
[NAME OF PERSON MAKING SERVICE]
[PROPOSED] ORDER ON MOTION IN LIMINE
IN THE CIRCUIT COURT OF [COUNTY / CITY OF ST. LOUIS], MISSOURI
| Party | Role |
|---|---|
| [PLAINTIFF NAME] | Plaintiff |
| v. | |
| [DEFENDANT NAME] | Defendant |
Case No.: [________] Division: [________]
The Court has considered the Motion, response, offers of proof, and [HEARING, IF ANY]. As to [SPECIFIC EVIDENCE OR ARGUMENT], the Motion is [GRANTED / DENIED / DEFERRED / GRANTED IN PART]. The ruling is limited to [EXACT SCOPE AND ANY PERMITTED PURPOSE]. Before mentioning an excluded or deferred matter in the jury's presence, counsel shall [REQUEST A RULING OUTSIDE THE JURY'S PRESENCE / FOLLOW OTHER DIRECTION].
Dated: [DATE]
____________________________
Circuit Judge
About this template
- Last updated
- November 9, 2026
- Citations checked
- November 9, 2026
- Jurisdiction
- Missouri
- Category
- Litigation & Court Documents
Legal authority
- Mo. Rev. Stat. § 490.065.1-.2 (expert testimony; proceeding-specific expert standards)
- Mo. Rev. Stat. § 491.060 (witness competency and listed communication bars)
- Mo. Sup. Ct. R. 78.07(a) (jury-trial error raised in new-trial motion, subject to exceptions)
- Mo. Sup. Ct. R. 43.01 (service of motion and certificate)
- Mo. Sup. Ct. R. 55.03(a) (filing signature)
- Holdeman v. Stratman, No. WD80586 (Mo. Ct. App. Aug. 28, 2018) (logical and legal relevance)
These are the filings that drive a lawsuit through the system: complaints, answers, motions, briefs, discovery requests and responses, and post-judgment papers. Each has its own format requirements under federal and state procedural rules, and each has a deadline that cannot be missed without consequences. Clean, procedurally correct filings move a case forward; sloppy ones invite motions to strike, amended responses, and avoidable delays.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
A reviewer verified this template's legal citations against the official source on November 9, 2026.
Mo. Rev. Stat. § 490.065.1 (probate proceedings) (checked November 9, 2026): "or in all proceedings before the probate division of the circuit court"
Mo. Rev. Stat. § 491.060 (checked November 9, 2026): "A person who is mentally incapacitated at the time of his or her production for examination"
Holdeman v. Stratman, No. WD80586 (Mo. Ct. App. Aug. 28, 2018) (checked November 9, 2026): "carefully, conscientiously, and continuously evaluated the facts and circumstances of this particular case"
Holdeman v. Stratman, No. WD80586, at 6–7 (Mo. Ct. App. Aug. 28, 2018) (checked November 9, 2026): "if the cost outweighs the usefulness, then the evidence is not legally relevant, and the court should exclude it"
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