Hutchinson, B. v. Verstraeten, T., 304 A.3d 1268

Brenda and Douglas Hutchinson sued Dr. Thierry Verstraeten and the Eye Clinic for medical malpractice and corporate negligence after Brenda was blinded in her right eye; the central factual dispute was whether an injection was placed into the eyeball.
Hutchinsons alleged the Eye Clinic altered electronic and paper medical records to conceal the error and relied on Jessica Page, an expert in Health Information Technology and Medflow operations, who issued three reports identifying missing/altered audit-trail entries, implausible exports, non‑care‑provider edits, altered handwritten notes, and invalid e‑signatures.
The trial court ordered production of the electronic audit trail; plaintiffs contended the produced audit logs were incomplete and moved for sanctions; defendants produced additional audit exports that plaintiffs still challenged.
Days before trial the Eye Clinic moved in limine to exclude Page; the court barred her testimony, finding audit‑trail issues irrelevant at trial, likely to confuse the jury, and that Page exceeded her expertise.
The case went to jury; verdict and post‑trial relief favored defendants. On appeal the Hutchinsons asserted the exclusion of Page and related evidentiary exclusions warranted reversal; the Superior Court affirmed, reviewing the trial court’s rulings for abuse of discretion and rejecting the Hutchinsons’ de novo relevancy argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by excluding expert Jessica Page	Page's testimony was relevant to show electronic/paper record alterations and support malpractice/corporate negligence claims	Page was not qualified for the handwriting/audit‑trail conclusions; testimony was irrelevant and would confuse the jury	Affirmed — exclusion did not constitute an abuse of discretion; trial court reasonably found relevance/qualification and jury‑confusion concerns under Pa.R.E. 401/403
Whether exclusion of evidence prevented an adverse‑inference instruction for intentional alteration	Excluded evidence was necessary to establish intentional record alteration and justify an adverse inference	Evidence was irrelevant; no proof alterations benefitted defendant; admitting it would cause confusion	Affirmed — plaintiffs failed to show trial court abused discretion in excluding the evidence or in denying basis for an adverse‑inference charge
Whether exclusion precluded spoliation/punitive‑damages jury charge	Exclusion foreclosed jury from spoliation/punitive instructions tied to alleged intentional destruction/alteration	Same relevance/qualification and jury‑confusion arguments; no abuse shown	Affirmed — appellate court required a showing of abuse of discretion which plaintiffs did not make; rulings upheld

Cohen v. Albert Einstein Med. Ctr., 592 A.2d 720 (Pa. Super. 1991) (earlier panel applied a de novo relevancy approach; Superior Court explains that approach was abrogated by the Rules of Evidence)
Rohe v. Vinson, 158 A.3d 88 (Pa. Super. 2016) (admissibility/exclusion of evidence reviewed for abuse of discretion)
Commonwealth v. Baker, 766 A.2d 328 (Pa. 2001) (framework for when an appellate court may find an abuse of discretion)
Womer v. Hilliker, 908 A.2d 269 (Pa. 2006) (describes forms of abuse of discretion)
Johnson v. Johnson, 222 A.3d 787 (Pa. Super. 2019) (reiterates abuse‑of‑discretion is more than mere error of judgment)