Missouri Court of Appeals, Eastern District / Aug 21, 2018
Joan Koelling, Appellant, vs. Mercy Hospitals East Communities d/b/a Mercy Hospital Washington, Mercy Clinic Surgical Specialists LLC, Thomas B. Riechers, M.D. and Mercy Clinic East Communities, Respondents.
Joan Koelling sued Mercy Hospitals and Dr. Thomas Riechers for medical malpractice, alleging negligence in her post-operative care. A jury returned a verdict for the defendants. On appeal, Koelling argued the trial court abused its discretion by excluding evidence of the defense's expert witness, Dr. Kralovich's, prior involvement as a defendant in medical malpractice lawsuits, which Koelling sought to introduce to show bias. The Eastern District reversed and remanded, holding that the trial court abused its discretion by entirely prohibiting inquiry into the expert's litigation history, as such evidence was relevant to demonstrate bias and its exclusion prejudiced Koelling.