Filippelli v. Saint Mary's Hospital

Summary

The court affirmed the judgment for the defendants, holding that the trial court acted within its discretion in limiting the plaintiff’s use of a medical journal article to impeach a fact witness and to cross-examine the defendants’ expert. The court also upheld the exclusion of questioning about the expert’s prior work for the defendant physician because that evidence concerned a collateral matter and posed a substantial risk of unfair prejudice. Although the trial court improperly denied an offer of proof and refused to mark a document for identification, those errors were harmless because the record was otherwise adequate for appellate review.