Aguilar v. Coonrod
262 P.3d 671
| Idaho | 2011Background
- Maria Aguilar died from a pulmonary embolus after multiple consultations; Aguilars sued Dr. Coonrod, Primary Health, and others formerly named; by trial, Chai and Long were dismissed or settled, leaving Newman, Coonrod, and Primary Health; trial included a discovery dispute over Dr. Blaylock, the Aguilars' expert; district court barred Coonrod from presenting/readings related to Blaylock’s opinions about Long/Chai; court held I.C. § 6-1603 applies per claimant, not per action; judgment affirmed for the Aguilars.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion barring Dr. Blaylock in trial | Aguilars argue proper disclosure allowed cross | Coonrod asserts disclosure was adequate | No abuse; bar upheld |
| Whether the court properly barred reading Blaylock's deposition | Aguilars rely on admissibility under Rule 32 | Coonrod argues deposition could be read | No abuse; deposition reading barred |
| Whether noneconomic damages cap applies per claimant or per action | Cap should apply per claimant | Cap should apply per action | Cap applies per claimant (per-person basis) |
| Whether the district court correctly interpreted the noneconomic damages cap statute | Statutory interpretation favors per-claimant | Statutory interpretation favors per-claimant | Statute interpreted as per claimant; per-person limit applies |
Key Cases Cited
- White v. Mock, 104 P.3d 356 (Idaho 2004) (abuse of discretion standard for expert evidence)
- Kuhn v. Coldwell Banker Landmark, Inc., 245 P.3d 992 (Idaho 2010) (abuse of discretion; new-trial standard)
- Clark v. Klein, 45 P.3d 810 (Idaho 2002) (substantial-right impact on evidentiary rulings)
- Wasden v. Maybee, 224 P.3d 1109 (Idaho 2010) (statutory interpretation; plain-meaning approach)