Hill v. State (1996)
In Hill v. State, 54 Ark. App. 380, 927 S.W.2d 820 (1996) the evidence excluded by the trial court was also the subject of a motion in limine by the State. There, Hill desired to impeach the State's witness, a police officer, through testimony that the officer had left the police force after filing a false police report and giving a false statement about his police car having been stolen. The court granted the State's motion in limine.
On appeal, the State contended that since Hill did not proffer the excluded testimony, the court's error in excluding it was not preserved. We held that the issue was preserved because, "under these facts, there is no question about the substance of the testimony." Hill, 54 Ark. App. at 381, 927 S.W.2d at 822.