Our supreme court has advised against conducting mini-trials on other conduct. People v. Brown, 319 Ill.App.3d 89, 96, 745 N.E.2d 173, 181 (2001) (citing People v. McKibbins, 96 Ill.2d 176, 186-87, 449 N.E.2d 821, 826 (1983)). As such, trial courts are to "carefully limit evidence of other conduct to evidence relevant to the issue on which the other conduct is admitted."
. The court in Bedoya relied on Brown, 319 Ill. App. 3d 89, People v. Thigpen, 306 Ill. App. 3d 29 (1999), People v. Bennett, 281 Ill. App. 3d 814 (1996), and Nunley 271 Ill. App. 3d 427, in its analysis of whether the other-crimes evidence amounted to a mini-trial. Bedoya, 325 Ill. App. 3d at 940-41
Defendant, however, neither requested such limiting instructions at trial nor provided us authority to show the absence of such admonitions is reversible error. Defendant relies on this court's decision in People v. Brown, 319 Ill. App. 3d 89, 745 N.E.2d 173 (2001). In Brown, we "suggested" these admonitions:
¶ 26 Defendant also argues the facts of this case are similar to those in People v. Salem, 2016 IL App (3d) 120390, and People v. Brown, 319 Ill.App.3d 89 (2001). In Salem, "the jury received four times the amount of evidence for the uncharged crimes" as compared to the charged offenses.
¶ 30 Trial courts should carefully limit evidence of other conduct of the defendant unless it is relevant to show intent, motive, modus operandi, identity, absence of mistake, or any relevant fact other than propensity. People v. Brown, 319 Ill. App. 3d 89, 96-97 (2001). Evidence of a defendant's prior acts of violence toward a family member or victim can be properly admitted as evidence of the defendant's intent, state of mind, motive, absence of mistake, or inclination to harm the victim.
¶ 30 "Because the trial court rules on a motion in limine before hearing the full evidence at trial, trial courts should be cautious in making broad rulings on motions in limine." People v. Brown, 319 Ill. App. 3d 89, 96, 745 N.E.2d 173, 181 (2001). The Second District has elaborated further and stated:
¶ 30 "Because the trial court rules on a motion in limine before hearing the full evidence at trial, trial courts should be cautious in making broad rulings on motions in limine." People v. Brown, 319 Ill. App. 3d 89, 96, 745 N.E.2d 173, 181 (2001). The Second District has elaborated further and stated:
We acknowledge the trial court's predicament, but we hold that defendant must be granted new trials because the cumulative error in this case was so egregious. ¶ 81 Our holding that defense counsel did not invite the jury instruction error is further supported by People v. Brown, 319 Ill.App.3d 89, 99, 253 Ill.Dec. 399, 745 N.E.2d 173 (2001), where the trial court used a flawed version of IPI Criminal 4th No. 3.14 such that the jury was not informed that the other-conduct evidence could be considered solely on the issues previously enumerated.
¶ 7 Generally, “[t]o preserve an issue for appeal, the defendant must have raised the issue in a motion in limine or an objection at trial and also in a posttrial motion.” People v. Brown, 319 Ill.App.3d 89, 96, 253 Ill.Dec. 399, 745 N.E.2d 173, 181 (2001). The failure to properly preserve an issue for review results in forfeiture.
A trial court's decision to answer a jury question will not be disturbed absent an abuse of discretion. People v. Brown, 319 Ill. App. 3d 89, 100, 745 N.E.2d 173, 184 (2001). When faced with a jury question during deliberations, "the general rule is that the trial court has a duty to provide instruction to the jury where it has posed an explicit question or requested clarification on a point of law arising from facts about which there is doubt or confusion."