Loading…
The 12th/278th District Courts’ standing order in limine for civil jury trials (Madison County edition). Counsel may not raise before the jury — without a prior ruling — liability insurance, jurors’ insurance-industry ties, a defendant’s ability to pay a judgment, collateral-source payments, when/how counsel was retained, attorney’s fees, taxation of awards, offers of independent medical exams, prior criminal history, or substance use, and must instruct clients and non-adverse witnesses to comply.
Texas > Madison County > 12th & 278th District Courts. Shared 12th & 278th Judicial District instrument; Madison County edition.
STANDING ORDER IN LIMINE FOR CIVIL JURY TRIALS For the 12th Judicial District Court & 278th Judicial District Court During the trial of any civil jury case in the District Court, and unless expressly suspended with reference to a particular trial, counsel shall not, in the presence or hearing of the jury, the venire panel, or any member thereof, mention, reference, or suggest any of the matters set forth below without first approaching the bench and obtaining a ruling from the Court. Counsel shall also instruct their respective clients, client representatives, and non-adverse witnesses to strictly refrain from making such statements or references unless necessary to truthfully respond to an opposing party’s question. The following matters are prohibited from being raised in the presence of the jury unless authorized by the Court: 1. Insurance Coverage. Any reference to the existence or absence of liability insurance coverage, the involvement of an insurance company in retaining defense counsel, or paying defense costs or any portion of a resulting judgment, unless the insurer is a named defendant. 2. Juror Associations with the Insurance Industry. Inquiries regarding a juror’s or their family member’s connection with the insurance industry, unless: a) The juror’s information card reflects insurance industry employment; or b) The inquiry concerns experience adjusting or evaluating claims, without direct mention of “insurance.” 3. Responsibility for Judgment. References suggesting whether a named defendant may or may not pay a judgment. 4. Collateral Sources. Statements regarding payment of damages from any collateral source, including health or disability insurance, employee benefit plans, social security, government assistance, or subsidized medical care, unless a testifying provider’s unpaid charges or letter of protection is being referenced. 5. Retention of Counsel. Statements about when or how a party retained counsel—unless it relates to referrals to a healthcare provider whose testimony or records are introduced. 6. Attorneys’ Fees. References to the obligation to pay, or the basis for, attorneys' fees unless such fees are submitted to the jury for consideration. 7. Taxation of Awards. Statements regarding whether damages are or are not taxable. 8. Independent Medical Exams. Any offer or willingness of a party to undergo an independent medical or psychological evaluation. 9. Criminal History. References to a party or witness's prior criminal conduct unless there is admissible evidence of a conviction previously ruled allowable by the Court. 10. Substance Use. Statements concerning alcohol, tobacco, or drug use by any party or witness, unless specifically relevant to the claims or defenses. 11. Settlement or Mediation. Mention of any offers, discussions, or mediation efforts. 12. Discovery Disputes. Any reference to disputes or rulings concerning discovery. 13. Prior Legal Claims. Any party’s involvement in prior lawsuits or claims, unless relevant to a claimed injury in this matter. 14. Ex Parte Witness Statements. References to ex parte statements by non-party witnesses unless the witness testifies inconsistently with the statement. Properly introduced depositions and admissible business or medical records are excluded from this prohibition. 15. Absent Witness Testimony. Projections of what an unavailable witness might say, unless the statement is part of an admissible deposition. 16. Hearsay Medical Opinions. Hearsay statements regarding medical opinions or diagnoses conveyed by a provider to an injured party. 17. Visual Aids. Display of documents, photos, or demonstratives to the jury without prior admission into evidence or consent from counsel and/or the Court. 18. Requests for Stipulations. Demands for stipulations or factual admissions in the jury’s presence. 19. Requests for Production in Jury’s Presence. Any request that opposing counsel or parties produce materials, unless a document used to refresh recollection is at issue. 20. Discriminatory Appeals. Arguments urging jury bias for or against a party based on race, gender, religion, national origin, marital or economic status (except as permitted in a bifurcated trial’s second phase). 21. Social Impact Arguments. Suggestions that a verdict would influence insurance premiums, public pricing, or taxes. 22. Financial Hardship Appeals. Emotional appeals for damages based on a party’s potential financial hardship. 23. Golden Rule Argument. Suggestions that jurors place themselves in a party’s position. 24. Counsel’s Personal Credibility Opinion. Any personal opinion by counsel regarding the truthfulness of any witness. 25. Outcome-Based Argument. Predicting the effect of jury answers on the ultimate outcome, except for argument advocating a specific answer to a jury question. 26. Undisclosed Evidence or Witnesses. Introduction of evidence or witnesses not identified in response to proper discovery requests, unless the party first approaches the bench and obtains a ruling based on good cause or improper request scope. 27. Discovery-Based Objections. Any objections based on discovery violations must be raised outside the presence of the jury. Wherever feasible, such matters should be addressed at pretrial. SIGNED this the 15th day of December, 2025. [signature] David W. Moorman, Judge, 12th Judicial District [signature] Tracy Sorensen, Judge, 278th Judicial District
Reviewer note: AJR-2 cluster (12th/278th/506th). Source instrument read via vision/text lane; classified RULE under the records-vs-rules doctrine. Composed benchpath-ajr2-cluster. Applicability 2026-09-09 (fix program 2026-09-09, Phase 5, audit M7): specific -> universal — the row binds every court in its state/circuit/county scope and names no court, judge or division. [RECOMPOSED 2026-09-21 (corpus-0920 P7, digital-layer lane): the full text of the registered file (sha256 6ac8f54d1a18..., 2 pages) replaces the earlier 418-character abstract. Method: pypdfium2 text layer reflowed page-aware, cross-checked word-by-word against PyMuPDF (0 substantive difference(s), 1 page-furniture), owner-corpus candidate sentences 100% (5/5) matched, 0 running header/footer line(s) removed, no U+FFFD/U+FFFE/form-feed debris. NOT yet checked page by page against the render, so confidence is medium with an open re-verification task; flip to high when a reviewer has read every page against the PDF. benchpath-tx-corpus0920-p7-2026-09-21] [BY-EYE CHECK 2026-09-21 (corpus-0920 P11): every page of the registered file (sha256 6ac8f54d1a18..., 2 page(s)) read against the rendered PDF; file-stamp, caption and signature-block defects of the text layer corrected from the render; confidence lifted to high. benchpath-tx-corpus0920-p11-2026-09-21]
Standing order of the 109th Judicial District Court for every pending or later-filed case in Andrews, Winkler and Crane Counties: any attorney or self-represented litigant who uses any form of artificial intelligence for legal research or drafting in a case must, before using AI-generated information in a court submission or proceeding, sign and submit the court's certification form stating that all language, quotations, sources, citations, arguments and legal analysis created or contributed to by generative AI were verified as accurate by a human through traditional (non-AI) legal sources, and acknowledging responsibility and potential sanctions for their or their co-counsel's failure to comply. Effective immediately; in effect until rescinded or replaced.
Standing order of the 109th Judicial District Court for every pending or later-filed case in Andrews, Winkler and Crane Counties: any attorney or self-represented litigant who uses any form of artificial intelligence for legal research or drafting in a case must, before using AI-generated information in a court submission or proceeding, sign and submit the court's certification form stating that all language, quotations, sources, citations, arguments and legal analysis created or contributed to by generative AI were verified as accurate by a human through traditional (non-AI) legal sources, and acknowledging responsibility and potential sanctions for their or their co-counsel's failure to comply. Effective immediately; in effect until rescinded or replaced.