Vanoosting v. Sellars

Illinois Appellate Court
Civil Court
Jury Instructions
Citation
Case Number: 
2012 IL App (5th) 110365
Decision Date: 
Thursday, June 14, 2012
District: 
5th Dist.
Division/County: 
Union Co.
Holding: 
Reversed and remanded.
Justice: 
SPOMER
Jury verdict for Plaintiff for injuries from rear-end car accident. Court erred in barring Plaintiff from testifying that she did not seek further treatment for her injuries in three years prior to trial because she did not have health insurance. Per Illinois Rule of Evidence 105, the court, upon request, can restrict evidence to its proper purpose and scope. Court could have instructed jury by appropriately tailoring IPI 3.03 to facts. Contested testimony relates directly to key issue of extent of damages, including loss of normal life. (WELCH and CHAPMAN, concurring.)