In a personal injury case, in what circumstances will the defense rely solely on the law of in limine ruling in the context of improper jury instruction?

In the trial court, the defense relied solely on People v. Williams, supra, 17 Cal.4th 142. That case involved an improper jury instruction which described the decedent as a victim in a case in which the defendant claimed self defense. (Ibid.) Here, this label was used by the prosecutor, not the trial court, and, although the prosecutor was wrong to violate the in limine ruling, the jury had just been instructed that statements by counsel were not evidence and that it should not be influenced by sympathy, bias or prejudice.