evidentiary abuse of discretion standard in Pennsylvania

2018"When reviewing the denial of a motion in limine, [the Superior Court) applies an evidentiary abuse of discretion standard of review." Stokes, 78 A.3d at 654 (citation omitted). (citing Commonwealth v. Zugay, 745 A.2d 639 (Pa. Super. 2000), appeal denied, 795 A.2d 976 (Pa. 2000) (explaining that motion in limine procedure to obtain ruling on admissibility of As evidence prior to trial is similar to ruling on motion to suppress, and thus, standard of review of motion in limine is the same as motion to suppress).

2017In reviewing a challenge to a denial of a motion in limine, the· appellate court applies "an evidentiary abuse of discretion standard." Commonwealth v. Zugby, 745 A.2d 639, 645 (Pa.Super. 2000) (citation omitted).

2026Similarly, our standard of review for a trial court’s decision to grant or deny a motion in limine is “an evidentiary abuse of discretion standard of review.” Parr v. Ford Motor Co., 109 A.3d 682, 690 (Pa. Super. 2014) (en banc) (citation omitted).

2026A trial court’s decision to grant or deny a motion in limine is subject to an evidentiary abuse of discretion standard of review. -5- J-A26017-25 Parr v. Ford Motor Co., 109 A.3d 682, 690 (Pa. Super. 2014) (citation and quotation marks omitted), appeal denied, 123 A.3d 331 (Pa. 2015), cert. denied, 577 U.S. 1008 (2015); see also Ruff v. York Hosp., 257 A.3d 43, 58 (Pa. Super. 2021) (stating, “[w]hen reviewing a trial court’s ruling on a motion in limine, this Court applies an evidentiary abuse of discretion standard of review), appeal denied, 266 A.3d 1064 (Pa. 2021).

2025A trial court's decision to grant or deny a motion in limine “is subject to an evidentiary abuse of discretion standard of review.” Id.

2024Id. at 31- 32. “[A] court’s decision to grant or deny a motion in limine is subject to an evidentiary abuse of discretion standard of review.” Commonwealth v. Reese, 31 A.3d 708, 715 (Pa. Super. 2011) (en banc).

2016“When reviewing a ruling on a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Parker, 104 A.3d 17, 21 (Pa. Super. 2014) (citation omitted).

2015“When reviewing a ruling on a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Parker, 104 A.3d 17, 21 (Pa.Super. 2014) (quoting Commonwealth v. Orie, 88 A.3d 983, 1022 (Pa.Super. 2014)).

2026In reviewing the propriety of a trial court’s ruling on a motion in limine, “we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Mitchell, 902 A.2d 430, 455 (Pa. 2006).

2017S42038/17 "When reviewing the denial of a motion in limine, we apply an evidentiary abuse of discretion standard of review." Commonwealth v. Mitchell, 902 A.2d 430, 455 (Pa. 2006) (citation omitted).

2026It is well-settled that, in reviewing a trial court’s order granting or denying a motion in limine, “we apply an evidentiary abuse of discretion standard of review.”12 Commonwealth v. Stokes, 78 A.3d 644, 654 (Pa. Super. 2013) (stating that, “[t]he admissibility of evidence is a matter ____________________________________________ 11 The “business records” exception to the rule against hearsay is formally referred to as the “records of a regularly conducted activity” exception and is codified at Pennsylvania Rule of Evidence 803(6).

2018"When reviewing the denial of a motion in limine, [the Superior Court) applies an evidentiary abuse of discretion standard of review." Stokes, 78 A.3d at 654 (citation omitted). (citing Commonwealth v. Zugay, 745 A.2d 639 (Pa. Super. 2000), appeal denied, 795 A.2d 976 (Pa. 2000) (explaining that motion in limine procedure to obtain ruling on admissibility of As evidence prior to trial is similar to ruling on motion to suppress, and thus, standard of review of motion in limine is the same as motion to suppress).

2025We review “a trial court’s decisions regarding the admissibility of evidence for an abuse of discretion.” Commonwealth v. Jones, 240 A.3d 881 , 889 (Pa. 2020) (citation omitted); see also Commonwealth v. Ivy, 146 A.3d 241, 250 (Pa. Super. 2016) (“When ruling on a trial court’s decision to grant or deny a motion in limine, we apply an evidentiary abuse of discretion standard of review.”).

2025“Questions concerning the admissibility of evidence are within the sound discretion of the trial court and we will not reverse a trial court’s decision concerning admissibility of evidence absent an abuse of the trial court’s discretion.” Commonwealth v. Nestor, 314 A.3d 863, 869 (Pa. Super. 2024); see also Commonwealth v. Ivy, 146 A.3d 241, 250 (Pa. Super. 2016) (“When ruling on a trial court’s decision to grant or deny a motion in limine, we apply an evidentiary abuse of discretion standard of review.”).

2025In reviewing the disposition of a motion in limine, “we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Cook, 231 A.3d 913, 919 (Pa. Super. 2020) (citation omitted).

2024“When ruling on a trial court’s decision to grant or deny a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Cook, 231 A.3d 913, 919 (Pa. Super. 2020). “[A]n abuse - 35 - J-A06041-24 of discretion occurs only where the trial court has reached a conclusion that overrides or misapplies the law, or when the judgment exercised is manifestly unreasonable, or is the result of partiality, prejudice, bias or ill-will.” Id. (citation omitted).

2020“When ruling on a trial court’s decision to grant or deny a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Moser, 999 A.2d 602, 605 (Pa.Super. 2010) (citation omitted), appeal denied, 20 A.3d 485 (Pa. 2011). “[T]he admissibility of evidence is a matter addressed to the sound discretion of the trial court and . . . an appellate court may only reverse upon a showing that the trial court abused its discretion.” Commonwealth v. Cox, 115 A.3d 333, 336 (Pa.Super. 2015) (citations and internal quotation marks omitted), appeal denied, 124 A.3d 308 (P

2019Commonwealth v. Belknap, 105 A.3d 7, 9-10 (Pa. Super. 2014) (alterations in original and citations and quotation marks omitted); see also Commonwealth v. Moser, 999 A.2d 602, 605 (Pa. Super. 2010) (explaining that this Court applies an evidentiary abuse of discretion standard of review when ruling on a trial court’s decision to grant or deny a motion in limine).

2024Our standard of review of the trial court’s evidentiary decisions is well settled: “When ruling on a trial court’s decision to grant or deny a motion in -9- J-S43023-23 J-S43024-23 J-S43025-23 limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Belani, 101 A.3d 1156, 1160 (Pa.Super. 2014).

2024“When ruling on a trial court’s decision to grant or deny a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Belani, 101 A.3d 1156, 1160 (Pa.Super. 2014).

2024In addition, “[w]hen ruling on a trial court's decision to grant or deny a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Hutchison, 164 A.3d 494, 500 (Pa. Super. 2017) (quotations and citations omitted).

2024In addition, “[w]hen ruling on a trial court's decision to grant or deny a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Hutchison, 164 A.3d 494, 500 (Pa. Super. 2017) (quotations and citations omitted).

2024The “[a]dmission of evidence is within the sound discretion of the trial court and will be reversed only upon a showing that the trial court clearly abused its discretion.” Commonwealth v. Tyson, 119 A.3d 353 , 357 (Pa. Super. 2015) (en banc) (internal citation and quotation marks omitted); see also Commonwealth v. Hoover, 107 A.3d 723 , 729 (Pa. 2014) (noting that an appellate court applies an evidentiary abuse of discretion standard when reviewing the denial ____________________________________________ 4 We have reordered these arguments for ease of disposition. -4- J-A25027-23 of a motion i

2024The “[a]dmission of evidence is within the sound discretion of the trial court and will be reversed only upon a showing that the trial court clearly abused its discretion.” Commonwealth v. Tyson, 119 A.3d 353, 357 (Pa. Super. 2015) (en banc) ____________________________________________ 4 We have reordered these arguments for ease of disposition. -4- J-A25027-23 (internal citation and quotation marks omitted); see also Commonwealth v. Hoover, 107 A.3d 723, 729 (Pa. 2014) (noting that an appellate court applies an evidentiary abuse of discretion standard when reviewing the denial of a motion in

2024The “[a]dmission of evidence is within the sound discretion of the trial court and will be reversed only upon a showing that the trial court clearly abused its discretion.” Commonwealth v. Tyson, 119 A.3d 353 , 357 (Pa. Super. 2015) (en banc) (internal citation and quotation marks omitted); see also Commonwealth v. Hoover, 107 A.3d 723 , 729 (Pa. 2014) (noting that an appellate court applies an evidentiary abuse of discretion standard when reviewing the denial ____________________________________________ 4 We have reordered these arguments for ease of disposition. -4- J-A25027-23 of a motion i

2024The “[a]dmission of evidence is within the sound discretion of the trial court and will be reversed only upon a showing that the trial court clearly abused its discretion.” Commonwealth v. Tyson, 119 A.3d 353, 357 (Pa. Super. 2015) (en banc) ____________________________________________ 4 We have reordered these arguments for ease of disposition. -4- J-A25027-23 (internal citation and quotation marks omitted); see also Commonwealth v. Hoover, 107 A.3d 723, 729 (Pa. 2014) (noting that an appellate court applies an evidentiary abuse of discretion standard when reviewing the denial of a motion in

2020“When reviewing a ruling on a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Orie, 88 A.3d 983, 1022 (Pa.Super. 2014) (internal citation omitted).

2015“When reviewing a ruling on a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Parker, 104 A.3d 17, 21 (Pa.Super. 2014) (quoting Commonwealth v. Orie, 88 A.3d 983, 1022 (Pa.Super. 2014)).

2021The admission of evidence is committed to the sound discretion of the trial court, and a trial court’s ruling regarding the admission of evidence will not be disturbed on appeal “unless that ruling reflects ‘manifest unreasonableness, or partiality, prejudice, bias, or ill-will, or such lack of support to be clearly erroneous.’” Commonwealth v. Minich, 4 A.3d 1063, 1068 (Pa. Super. 2010) (citations omitted). ____________________________________________ 7 As we discuss infra, there is no reference to a “Meco Brown” in the motion in limine hearing transcript.

2016In Commonwealth v. Minich, 4 A.3d 1063 (Pa. Super. 2010), this Court explained: When ruling on a trial court’s decision to grant or deny a motion in limine, we apply an evidentiary abuse of discretion standard of review.

2026Appellant’s Brief, at 4 (unnecessary capitalization omitted). “[W]hen reviewing the denial of a motion in limine, we apply an evidentiary abuse of discretion standard of review[]” because “[t]he admission of evidence is committed to the sound discretion of the trial court[.]” Commonwealth v. Sami, 243 A.3d 991, 997 (Pa. Super. 2020) (citation omitted).

2025We have recounted that “when reviewing the denial of a motion in limine, we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Sami, 243 A.3d 991 , 997 - 12 - J-A26004-24 (Pa.Super. 2020) (cleaned up).

2021“A trial court’s decision to grant a motion in limine ‘is subject to an evidentiary abuse of discretion standard of review.’” In re Fiedler, 132 A.3d 1010, 1023 (Pa. Super. 2016).

2018“A trial court’s decision to grant a motion in limine is subject to an evidentiary abuse of discretion standard of review.” In re Fiedler, 132 A.3d 1010 , (Pa. Super. 2016).

2019Where an appellate court reviews the denial of a motion in limine, our courts apply “an evidentiary abuse of discretion standard of review.” Cmwlth. v. Hoover, 107 A.3d 723, 729 (Pa. 2014) (quoting Cmwlth. v. Rivera, 983 A.2d 1211, 1228 (Pa. 2009)).

2014It is well-established that the admissibility of evidence is within the discretion of the trial court, and such rulings will not Commonwealth v. Rivera, 983 A.2d 1211, 1228 (Pa. 2009).

2026See Frazer v. McEntire, 265 A.3d 777, 783 (Pa. Super. 2021).

2024“A trial court’s decision to grant a motion in limine is subject to an evidentiary abuse of discretion standard of review.” Frazer v. McEntire, 265 A.3d 777, 783 (Pa. Super. 2021) (cleaned up).

2023“When reviewing a trial court’s denial of a motion in limine, this Court applies an evidentiary abuse of discretion standard of review.” Commonwealth v. Schley, 136 A.3d 511, 514 (Pa. Super. 2016) (citation omitted).

2017“When reviewing a trial court’s denial of a motion in limine, this Court applies an evidentiary abuse of discretion standard of review.” -2- J-S52009-17 Commonwealth v. Schley, 136 A.3d 511, 514 (Pa. Super. 2016).

2020“We review a challenge to the denial of a motion in limine under an evidentiary abuse of discretion standard.” Commonwealth v. Hitcho, 123 A.3d 731, 747 (Pa. 2015).

2019“Initially, we note that, ‘[w]hen reviewing the denial of a motion in limine, we apply an evidentiary abuse of discretion standard of review.’” Commonwealth v. Hitcho, 123 A.3d 731, 747 (Pa. 2015) (citation omitted).

2019“Questions concerning the admissibility of evidence lie within the sound discretion of the trial court, and we will not reverse the court’s decision absent a clear abuse of discretion. ‘An abuse of discretion may not be found merely because an appellate court might have reached a different conclusion, but requires a manifest unreasonableness, or partiality, prejudice, bias, or ill- will, or such lack of support as to be clearly erroneous.’” Grady v. Frito-Lay, Inc., [] 839 A.2d 1038, 1046 ([Pa/] 2003).

2016See Commonwealth v. Topa, 369 A.2d 1277, 1282 (Pa. 1977); see also Grady v. Frito-Lay, Inc., 839 A.2d 1038 (Pa. 2003) (continuing to apply Frye rule in Pennsylvania). -9- J-A17014-16 A trial court’s decision to grant or deny a motion in limine is subject to an evidentiary abuse of discretion standard of review.

2018Commonwealth v. Williams, 91 A.3d 240, 248 (Pa. Super. 2014) (en banc) (quotation marks and citations omitted).

2017“A trial court’s decision to … deny a motion in limine is generally subject to an evidentiary abuse of discretion standard of review.” Commonwealth v. Williams, 91 A.3d 240, 248 (Pa. Super. 2014) (en - 15 - J-A29035-16 banc).

2017In reviewing the denial of a motion in limine, “we apply an evidentiary abuse of discretion standard of review.” Commonwealth v. Owens, 929 A.2d 1187, 1190 (Pa. Super. 2007).

2017Commonwealth v. Bozyk, 987 A.2d 753 , 755–756 (Pa.Super.2009) (quoting Commonwealth v. Owens, 929 A.2d 1187, 1190 (Pa.Super.2007)).

2017Commonwealth v. Bozyk, 987 A.2d 753 , 755–756 (Pa.Super.2009) (quoting Commonwealth v. Owens, 929 A.2d 1187, 1190 (Pa.Super.2007)).

2015Commonwealth v. Bozyk, 987 A.2d 753 , 755–756 (Pa. Super.2009) (citations omitted).

2026For ease of reference, we refer to the records of a regularly conducted activity exception as the business records exception. 12 “Consistent with [Pennsylvania Rule of Evidence] 103(a), a motion in limine may preserve an objection for appeal without any need to renew the objection at trial, but only if the trial court definitively rules on the motion.” Commonwealth v. Reich, 340 A.3d 997 , 1008 (Pa. Super. 2025), citing Blumer v. Ford Motor Co., 20 A.3d 1222, 1232 (Pa. Super. 2011), appeal denied, 49 A.3d 441 (Pa. 2012).

2015“A motion in limine may preserve an objection for appeal without any need to renew the objection at trial, but only if the trial court clearly and definitively rules on the motion.” Blumer v. Ford Motor Co., 20 A.3d 1222, 1232 (Pa.Super. 2011), appeal denied, 616 Pa. 649 , 49 A.3d -5- J-A28010-15 441 (2012). “[A] court’s decision to grant or deny a motion in limine is subject to an evidentiary abuse of discretion standard of review.” Commonwealth v. Reese, 31 A.3d 708, 715 (Pa.Super. 2011) (en banc).

2025It is axiomatic that “[o]nly relevant evidence is admissible at trial.” Commonwealth v. Christine, 125 A.3d 394, 398 (Pa. 2015) (citing Pa.R.E. 402).

2024“An abuse of discretion will not be found based on a mere error of judgment, but rather exists where the court has reached a conclusion that overrides or misapplies the law, or where the judgment exercised is manifestly unreasonable, or the result of partiality, prejudice, bias or ill-will.” Commonwealth v. Christine, 125 A.3d 394 , 398 (Pa. 2015) (cleaned up).

2024“An abuse of discretion is not merely an error of judgment, but if in reaching a conclusion the law is overridden or misapplied, or the judgment exercised is manifestly unreasonable, or the result of partiality, prejudice, bias or ill-will, as shown by the evidence or the record, discretion is abused.” Commonwealth v. Walker, 92 A.3d 766 , 772-73 (Pa. 2014) (internal quotation marks and citations omitted).

2024“An abuse of discretion is not merely an error of judgment, but if in reaching a conclusion the law is overridden or misapplied, or the judgment exercised is manifestly unreasonable, or the result of partiality, prejudice, bias or ill-will, as shown by the evidence or the record, discretion is abused.” Commonwealth v. Walker, 92 A.3d 766, 772-73 (Pa. 2014) (internal quotation marks and citations omitted).

2023"Accordingly, a ruling admitting evidence will not be disturbed on appeal unless that ruling reflects manifest unreasonableness, or partiality, prejudice, bias, or ill-will, or such lack of support to be clearly erroneous." Commonwealth v. Huggins, 68 A.3d 962, 966 (Pa.Super. 2013) (internal citations and quotation marks omitted).

2023"Accordingl y, a ruling admitting evidence will not be disturbed on appeal unless that ruling reflects manifest unreasonab leness, or partiality, prejudice, bias, or ill-will, or such lack of support to be clearly erroneous." Commonwe alth v. Huggins, 68 A.3d 962, 966 (Pa.Super. 2013) (internal citations and quotation marks omitted).