Madison County, Illinois, et al. v. Reginald Pittman

Appellate courts have universally accepted the abuse of discretion standard for reviewing evidentiary decisions. Under this standard, the circuit court determines if the district court made a legally erroneous decision that was prejudicial. In this case, the United States Court of Appeals for the Seventh Circuit overturned the jury’s verdict after concluding the District Court erroneously excluded from evidence a videotaped witness interview and the transcript from that interview. The specific questions presented are: I. Did the Circuit Court have authority to make a finding of fact contrary to the District Court’s findings regarding the existence of an agreement as to the admissibility of the videotaped interview and transcript? II. Is a Circuit Court’s determination that excluded evidence “could have” affected the jury’s verdict sufficient to constitute prejudice when applying an abuse of discretion standard? III. Can a District Court’s decision to exclude cumulative evidence constitute prejudice when applying an abuse of discretion standard?