Robinson v. Paul Ray Taylor, M.D.
356 P.3d 1230
Utah2015Background
- Robinsons sued Dr. Taylor for wrongful death due to alleged medical malpractice in prescribing methadone.
- Dr. Taylor was convicted of a federal felony for distributing controlled substances; the conviction was admitted at trial for impeachment.
- Jury found negligence and awarded damages; conviction was later challenged on appeal.
- Trial court admitted the felony conviction under Utah Rules of Evidence 608(b) and 609(a)(1) and (a)(2).
- Appellate court reversed and remanded for a new trial, holding admission under these rules was an abuse of discretion.
- Dissent argued the conviction had substantial probative value to credibility and supported affirmance of admission.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 608(b) permits impeachment by criminal conviction | Robinson argues conviction is probative of credibility | Taylor argues 608(b) governs non-conviction acts | Rule 608(b) does not cover convictions; admission was an abuse of discretion |
| Whether Rule 609(a)(2) requires automatic admission for the narcotics conviction | Robinson contends automatic admission applies | Taylor contends conviction lacks dishonest-act element | Rule 609(a)(2) does not apply; conviction not per se admissible under this subsection |
| Whether Rule 609(a)(1)(A) admission was proper in a civil case | Robinson claims credibility concern supports admission | Taylor argues risk of unfair prejudice outweighs probative value | Admission under 609(a)(1)(A) was abuse of discretion due to unfair prejudice outweighing probative value |
| Whether the evidentiary error was harmless | Conviction evidence could have influenced the verdict | Trial could stand without conviction evidence | The error was not harmless; vacate verdict and remand for new trial |
Key Cases Cited
- State v. Mead, 2001 UT 58 (Utah 2001) (guides interpretation of evidentiary rules)
- State v. Gray, 717 P.2d 1313 (Utah 1986) (uniformity with federal rules of evidence)
- State v. Banner, 717 P.2d 1325 (Utah 1986) (factors for Rule 403 balancing in prior-conviction evidence)
- State v. Lucero, 2014 UT 15 (Utah 2014) (limits on Banner factors for 403 balancing in civil cases)
- State v. Emmett, 839 P.2d 781 (Utah 1992) (prior convictions probative of credibility under 609 and 404)