St. John v. PetersonAnnotate this Case
Lita St. John sued Dr. Linda Peterson, alleging medical malpractice in repairing a vesicovaginal fistula. The jury entered a verdict for Peterson. St. John appealed, arguing that the trial court erred in excluding evidence of other cases where Peterson failed to repair vesicovaginal fistulas. The Supreme Court held that the trial court misstated and apparently misapplied the balancing test of S.C. R. Evid. 403, which states that relevant evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice. Because it was possible that the exclusion of the evidence in all probability affected the outcome of the jury's verdict and thereby constituted prejudicial error, the Court reversed the judgment of the trial court and remanded.