Munn v. Algee - 924 F.2d 568 (5th Cir. 1991)

Rule:

Simply because the district court abuses its discretion in admitting his testimony does not entitle the appellant to relief. Fed. R. Evid. 103(a) indicates that the court should not reverse on the basis of erroneous evidentiary rulings unless a party's "substantial right" is affected. This question is not susceptible to mechanical analysis. Fed. R. Evid. 103 is silent as to what factors a court must consider in determining whether substantial rights have been affected, indicating that the court must proceed on a case-to-case basis rather than apply a mechanical rule. However, the court states that an error is harmless if the court is sure, after reviewing the entire record, that the error did not influence the jury or had but a very slight effect on its verdict.

Facts:

Plaintiff's wife died from a loss of blood after she and he refused a blood transfusion on the basis of their religious belief. Plaintiff brought suit against defendant in three separate capacities: (i) individually for his own injuries; (ii) as administrator of his deceased spouse’s estate; and (iii) on behalf of his children, who, along with the plaintiff, were the wrongful death beneficiaries under the Mississippi wrongful death statute, Miss. Code Ann. § 11-7-13 (Supp.1990). At trial, defendant argued that plaintiff's wife's refusal to accept blood transfusions was unreasonable and thus that the doctrine of avoidable consequences precluded any recovery. The jury concluded that plaintiff’s wife would not have died had she accepted blood transfusions and thus awarded the wrongful death beneficiaries no damages. Plaintiff moved for a new trial, asserting that the trial court erred, among others, in admitting evidence of Jehovah's Witnesses' beliefs and in allowing defendant to invoke the avoidable consequences doctrine.

Issue:

1. Did the trial court err in admitting evidence of plaintiff’s Jehovah's Witnesses' beliefs? 
2. Did the trial court err in allowing defendant to invoke the avoidable consequences doctrine?

Answer:

1) Yes, but the error was harmless. 2) No.

Conclusion:

The Court affirmed the trial court’s decision, finding no reversible error. While the Court agreed with the plaintiff that the evidence did not examine plaintiff's sincere beliefs and was not relevant under Fed. R. Evid. 401, the Court held that a substantial right of plaintiff was not affected and the error was harmless. Anent the second issue, the Court held that an injured plaintiff may not recover for damages that she did not take reasonable efforts to avoid, as such, the avoidable consequences doctrine was properly applied to preclude wrongful death recovery. The Court also held that proper application of the avoidable consequences doctrine did not violate the U.S. Const. amend. I.