Weaver v. McKnight, 313 Conn. 393

Summary

The Connecticut Supreme Court held that the trial court abused its discretion by precluding two board-certified obstetrician-gynecologists from testifying that untreated gestational diabetes caused a stillbirth. The court concluded that the experts’ relevant clinical experience qualified them to offer causation opinions and that challenges to the depth or factual basis of their opinions generally went to weight rather than admissibility. The court also addressed other evidentiary rulings likely to recur on remand and ordered a new trial.

Holdings

1. Trial court's decision to preclude the expert testimony contradicted the facts in the record and applicable law, thus amounting to an abuse of discretion.
2. Appellate Court's application of Porter analysis was improper because defendants did not raise a Porter claim in the trial court.
3. Trial court abused its discretion by precluding treating physician's opinion that patient had gestational diabetes as improper standard of care opinion.
4. Trial court improperly permitted cross-examination about censure because it constituted inadmissible extrinsic evidence of prior misconduct.

Questions Presented

1. Whether trial court abused its discretion in precluding two board-certified obstetrician/gynecologist experts from testifying about cause of stillbirth
2. Whether trial court properly precluded treating physician's opinion about gestational diabetes
3. Whether trial court properly precluded treating nurse's testimony about her suspicion of gestational diabetes
4. Whether trial court improperly allowed cross-examination about expert's censure by voluntary professional organization

Disposition

reversed_and_remanded