{ "id": 1033947, "name": "DEBRA L. BACHMAN, as Mother and Legal Guardian of the Estate and Person of Danielle L. Bachman, a Disabled Person, et al., Plaintiffs-Appellants, v. GENERAL MOTORS CORPORATION et al., Defendants-Appellees", "name_abbreviation": "Bachman v. General Motors Corp.", "decision_date": "2002-07-29", "docket_number": "No. 4-01-0237", "first_page": "760", "last_page": "808", "citations": [ { "type": "official", "cite": "332 Ill. App. 3d 760" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "581 N.E.2d 310", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1991, "pin_cites": [ { "page": "320", "parenthetical": "holding that the cumulative error doctrine did not apply where the \"few errors [that] occurred at trial\" did not prejudice the defendant" } ], "opinion_index": 0 }, { "cite": "220 Ill. App. 3d 890", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5276309 ], "year": 1991, "pin_cites": [ { "parenthetical": "holding that the cumulative error doctrine did not apply where the \"few errors [that] occurred at trial\" did not prejudice the defendant" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/220/0890-01" ] }, { "cite": "721 N.E.2d 769", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1999, "pin_cites": [ { "page": "776, 779", "parenthetical": "reversing award of punitive damages where 30 prior incidents reflected roughly 0.5% of production and 0.0000007% of estimated number of uses (cuts of meat)" } ], "opinion_index": 0 }, { "cite": "308 Ill. App. 3d 967", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 261320 ], "year": 1999, "pin_cites": [ { "page": "974-75, 979", "parenthetical": "reversing award of punitive damages where 30 prior incidents reflected roughly 0.5% of production and 0.0000007% of estimated number of uses (cuts of meat)" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/308/0967-01" ] }, { "cite": "384 N.E.2d 353", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1978, "pin_cites": [ { "page": "359" } ], "opinion_index": 0 }, { "cite": "74 Ill. 2d 172", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2994390 ], "year": 1978, "pin_cites": [ { "page": "186" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/74/0172-01" ] }, { "cite": "563 N.E.2d 397", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1990, "pin_cites": [ { "page": "401-02" }, { "page": "404, 408", "parenthetical": "reversing award of punitive damages where 94 prior accidents reflected about 0.003% of production and \"even smaller percentage\" of uses (gun)" } ], "opinion_index": 0 }, { "cite": "138 Ill. 2d 404", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5577071 ], "weight": 2, "year": 1990, "pin_cites": [ { "page": "414-16" }, { "page": "420, 430" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/138/0404-01" ] }, { "cite": "666 N.E.2d 704", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1996, "pin_cites": [ { "page": "711", "parenthetical": "appellate court reviews de novo a trial court's denial of a section 2 - 604.1 motion to amend" } ], "opinion_index": 0 }, { "cite": "281 Ill. App. 3d 733", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 150222 ], "year": 1996, "pin_cites": [ { "page": "742-43", "parenthetical": "appellate court reviews de novo a trial court's denial of a section 2 - 604.1 motion to amend" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/281/0733-01" ] }, { "cite": "393 N.E.2d 1223", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1979, "pin_cites": [ { "page": "1233", "parenthetical": "\"the plaintiff can only be awarded punitive damages where actual damage is shown\"" } ], "opinion_index": 0 }, { "cite": "75 Ill. App. 3d 298", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3276581 ], "year": 1979, "pin_cites": [ { "page": "310", "parenthetical": "\"the plaintiff can only be awarded punitive damages where actual damage is shown\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/75/0298-01" ] }, { "cite": "464 N.E.2d 651", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1984, "pin_cites": [ { "page": "655" } ], "opinion_index": 0 }, { "cite": "124 Ill. App. 3d 433", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3431190 ], "year": 1984, "pin_cites": [ { "page": "438" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/124/0433-01" ] }, { "cite": "734 N.E.2d 1012", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2000, "pin_cites": [ { "page": "1015" } ], "opinion_index": 0 }, { "cite": "315 Ill. App. 3d 1075", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 980620 ], "year": 2000, "pin_cites": [ { "page": "1078" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/315/1075-01" ] }, { "cite": "603 N.E.2d 508", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1992, "pin_cites": [ { "page": "512" } ], "opinion_index": 0 }, { "cite": "151 Ill. 2d 445", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3292317 ], "year": 1992, "pin_cites": [ { "page": "452-53" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/151/0445-01" ] }, { "cite": "682 N.E.2d 386", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1997, "pin_cites": [ { "page": "393" }, { "page": "393" } ], "opinion_index": 0 }, { "cite": "289 Ill. App. 3d 634", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 351090 ], "weight": 2, "year": 1997, "pin_cites": [ { "page": "643" }, { "page": "643" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/289/0634-01" ] }, { "cite": "665 N.E.2d 1260", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1996, "pin_cites": [ { "page": "1274" } ], "opinion_index": 0 }, { "cite": "172 Ill. 2d 213", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 55976 ], "year": 1996, "pin_cites": [ { "page": "242" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/172/0213-01" ] }, { "cite": "749 N.E.2d 434", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2001, "pin_cites": [ { "page": "440" } ], "opinion_index": 0 }, { "cite": "322 Ill. App. 3d 641", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 126376 ], "year": 2001, "pin_cites": [ { "page": "648" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/322/0641-01" ] }, { "cite": "614 N.E.2d 214", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1993, "pin_cites": [ { "page": "218" } ], "opinion_index": 0 }, { "cite": "244 Ill. App. 3d 260", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5102017 ], "year": 1993, "pin_cites": [ { "page": "266" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/244/0260-01" ] }, { "cite": "606 N.E.2d 500", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1992, "pin_cites": [ { "page": "502", "parenthetical": "\"It is well settled that a failure to specifically object to a special interrogatory will waive any objection in the giving of that special interrogatory\"" } ], "opinion_index": 0 }, { "cite": "238 Ill. App. 3d 656", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5154926 ], "year": 1992, "pin_cites": [ { "page": "658", "parenthetical": "\"It is well settled that a failure to specifically object to a special interrogatory will waive any objection in the giving of that special interrogatory\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/238/0656-01" ] }, { "cite": "755 N.E.2d 1021", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 2001, "pin_cites": [ { "page": "1029" }, { "page": "1029" } ], "opinion_index": 0 }, { "cite": "324 Ill. App. 3d 568", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 256271 ], "weight": 2, "year": 2001, "pin_cites": [ { "page": "576" }, { "page": "576" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/324/0568-01" ] }, { "cite": "740 N.E.2d 1131", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2000, "pin_cites": [ { "page": "1140" } ], "opinion_index": 0 }, { "cite": "317 Ill. App. 3d 1026", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1026015 ], "weight": 2, "year": 2000, "pin_cites": [ { "page": "1037" }, { "page": "1037" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/317/1026-01" ] }, { "cite": "758 N.E.2d 442", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 3, "year": 2001, "pin_cites": [ { "page": "451" }, { "page": "451" }, { "page": "451" } ], "opinion_index": 0 }, { "cite": "325 Ill. App. 3d 458", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 570055 ], "weight": 3, "year": 2001, "pin_cites": [ { "page": "469" }, { "page": "469" }, { "page": "469" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/325/0458-01" ] }, { "cite": "762 N.E.2d 710", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2002, "pin_cites": [ { "page": "714", "parenthetical": "a reviewing court will not reverse a trial court's decision to grant or deny a motion in limine absent a clear abuse of discretion" } ], "opinion_index": 0 }, { "cite": "327 Ill. App. 3d 338", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 79548 ], "year": 2002, "pin_cites": [ { "page": "343", "parenthetical": "a reviewing court will not reverse a trial court's decision to grant or deny a motion in limine absent a clear abuse of discretion" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/327/0338-01" ] }, { "cite": "731 N.E.2d 987", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2000, "pin_cites": [ { "page": "991", "parenthetical": "concluding that error in admitting certain evidence was harmless when the jury was \"presented with [the same] version of events independently of any prejudicial effect that the error may have had\"" } ], "opinion_index": 0 }, { "cite": "314 Ill. App. 3d 268", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 140285 ], "year": 2000, "pin_cites": [ { "page": "273", "parenthetical": "concluding that error in admitting certain evidence was harmless when the jury was \"presented with [the same] version of events independently of any prejudicial effect that the error may have had\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/314/0268-01" ] }, { "cite": "568 N.E.2d 46", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1991, "pin_cites": [ { "page": "50" } ], "opinion_index": 0 }, { "cite": "209 Ill. App. 3d 128", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2541458 ], "year": 1991, "pin_cites": [ { "page": "135" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/209/0128-01" ] }, { "cite": "754 N.E.2d 839", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2001, "pin_cites": [ { "page": "849" } ], "opinion_index": 0 }, { "cite": "324 Ill. App. 3d 114", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 256282 ], "year": 2001, "pin_cites": [ { "page": "124" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/324/0114-01" ] }, { "cite": "671 N.E.2d 1141", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1996, "pin_cites": [ { "page": "1147" } ], "opinion_index": 0 }, { "cite": "284 Ill. App. 3d 53", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1260404 ], "year": 1996, "pin_cites": [ { "page": "62" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/284/0053-01" ] }, { "cite": "592 N.E.2d 997", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1992, "pin_cites": [ { "page": "1022" } ], "opinion_index": 0 }, { "cite": "148 Ill. 2d 196", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3283395 ], "year": 1992, "pin_cites": [ { "page": "252" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/148/0196-01" ] }, { "cite": "605 N.E.2d 1373", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1992, "pin_cites": [ { "page": "1385", "parenthetical": "the jury's viewing of property involved in the litigation \"does not constitute evidence, but is merely a device to facilitate the jury's understanding and application of the evidence to the issues presented at trial\"" } ], "opinion_index": 0 }, { "cite": "238 Ill. App. 3d 410", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5154699 ], "year": 1992, "pin_cites": [ { "page": "427", "parenthetical": "the jury's viewing of property involved in the litigation \"does not constitute evidence, but is merely a device to facilitate the jury's understanding and application of the evidence to the issues presented at trial\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/238/0410-01" ] }, { "cite": "729 N.E.2d 536", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 4, "year": 2000, "pin_cites": [ { "page": "545" }, { "page": "545" }, { "page": "545" }, { "page": "544" } ], "opinion_index": 0 }, { "cite": "313 Ill. App. 3d 326", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 186500 ], "weight": 4, "year": 2000, "pin_cites": [ { "page": "337" }, { "page": "337" }, { "page": "337" }, { "page": "336" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/313/0326-01" ] }, { "cite": "576 N.E.2d 311", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1991, "pin_cites": [ { "page": "320", "parenthetical": "\"[A] 'just order' under Rule 219(c) is one which, to the degree possible, ensures both the accomplishment of discovery and a trial on the merits\"" } ], "opinion_index": 0 }, { "cite": "216 Ill. App. 3d 360", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5287349 ], "year": 1991, "pin_cites": [ { "page": "373", "parenthetical": "\"[A] 'just order' under Rule 219(c) is one which, to the degree possible, ensures both the accomplishment of discovery and a trial on the merits\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/216/0360-01" ] }, { "cite": "606 N.E.2d 423", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1992, "pin_cites": [ { "page": "430", "parenthetical": "\"A party cannot complain of evidence which he himself introduced or brought out\"" }, { "page": "430", "parenthetical": "\"A party cannot complain of evidence which he himself introduced or brought out\"" } ], "opinion_index": 0 }, { "cite": "238 Ill. App. 3d 558", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5156783 ], "weight": 2, "year": 1992, "pin_cites": [ { "page": "568", "parenthetical": "\"A party cannot complain of evidence which he himself introduced or brought out\"" }, { "page": "568" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/238/0558-01" ] }, { "cite": "724 N.E.2d 115", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1999, "pin_cites": [ { "page": "127" } ], "opinion_index": 0 }, { "cite": "311 Ill. App. 3d 7", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 415306 ], "year": 1999, "pin_cites": [ { "page": "23" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/311/0007-01" ] }, { "cite": "642 N.E.2d 1348", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1994, "pin_cites": [ { "page": "1352", "parenthetical": "\"When a motion in limine is denied, the unsuccessful movant must specifically object to the evidence when it is offered by the other party at trial\"" } ], "opinion_index": 0 }, { "cite": "268 Ill. App. 3d 157", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 381891 ], "year": 1994, "pin_cites": [ { "page": "162", "parenthetical": "\"When a motion in limine is denied, the unsuccessful movant must specifically object to the evidence when it is offered by the other party at trial\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/268/0157-01" ] }, { "cite": "738 N.E.2d 542", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2000, "pin_cites": [ { "page": "552", "parenthetical": "\"Because an in limine order always remains subject to reconsideration by the court during trial, an in limine motion, whether granted or denied, does not preserve issues for review\"" } ], "opinion_index": 0 }, { "cite": "316 Ill. App. 3d 1121", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1096655 ], "year": 2000, "pin_cites": [ { "page": "1132", "parenthetical": "\"Because an in limine order always remains subject to reconsideration by the court during trial, an in limine motion, whether granted or denied, does not preserve issues for review\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/316/1121-01" ] }, { "cite": "708 N.E.2d 1187", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1999, "pin_cites": [ { "page": "1191" } ], "opinion_index": 0 }, { "cite": "303 Ill. App. 3d 872", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 511323 ], "year": 1999, "pin_cites": [ { "page": "877" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/303/0872-01" ] }, { "cite": "728 N.E.2d 1230", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2000, "pin_cites": [ { "page": "1232-33" } ], "opinion_index": 0 }, { "cite": "313 Ill. App. 3d 356", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 186484 ], "weight": 2, "year": 2000, "pin_cites": [ { "page": "359" }, { "page": "361" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/313/0356-01" ] }, { "cite": "753 N.E.2d 353", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2001, "pin_cites": [ { "page": "361" } ], "opinion_index": 0 }, { "cite": "323 Ill. App. 3d 1067", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 171580 ], "year": 2001, "pin_cites": [ { "page": "1075" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/323/1067-01" ] }, { "cite": "651 N.E.2d 1071", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1995, "pin_cites": [ { "page": "1081" } ], "opinion_index": 0 }, { "cite": "166 Ill. 2d 48", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 198891 ], "year": 1995, "pin_cites": [ { "page": "68" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/166/0048-01" ] }, { "cite": "709 N.E.2d 982", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1999, "pin_cites": [ { "page": "985", "parenthetical": "when an objection is made in the trial court, the specific grounds must be stated, and other grounds not stated are forfeited on appeal" } ], "opinion_index": 0 }, { "cite": "304 Ill. App. 3d 304", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 564547 ], "year": 1999, "pin_cites": [ { "page": "309", "parenthetical": "when an objection is made in the trial court, the specific grounds must be stated, and other grounds not stated are forfeited on appeal" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/304/0304-01" ] }, { "cite": "634 N.E.2d 1163", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1994, "pin_cites": [ { "page": "1167", "parenthetical": "Cook, J., specially concurring" } ], "opinion_index": 0 }, { "cite": "261 Ill. App. 3d 904", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5372968 ], "year": 1994, "pin_cites": [ { "page": "909", "parenthetical": "Cook, J., specially concurring" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/261/0904-01" ] }, { "cite": "651 N.E.2d 617", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1995, "pin_cites": [ { "page": "624" } ], "opinion_index": 0 }, { "cite": "272 Ill. App. 3d 925", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 252027 ], "year": 1995, "pin_cites": [ { "page": "935-36" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/272/0925-01" ] }, { "cite": "601 N.E.2d 1055", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1992, "pin_cites": [ { "page": "1064" } ], "opinion_index": 0 }, { "cite": "235 Ill. App. 3d 292", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5784172 ], "year": 1992, "pin_cites": [ { "page": "305" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/235/0292-01" ] }, { "cite": "679 N.E.2d 1244", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1997, "pin_cites": [ { "page": "1249" } ], "opinion_index": 0 }, { "cite": "288 Ill. App. 3d 90", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1596914 ], "year": 1997, "pin_cites": [ { "page": "98" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/288/0090-01" ] }, { "cite": "728 N.E.2d 1278", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2000, "pin_cites": [ { "page": "1286" } ], "opinion_index": 0 }, { "cite": "313 Ill. App. 3d 107", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 186516 ], "year": 2000, "pin_cites": [ { "page": "114" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/313/0107-01" ] }, { "cite": "474 N.E.2d 814", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1985, "pin_cites": [ { "page": "821", "parenthetical": "holding that the trial court erred by allowing the plaintiff to present accident reconstruction evidence but precluding the defendant from presenting such evidence" } ], "opinion_index": 0 }, { "cite": "130 Ill. App. 3d 662", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3492890 ], "year": 1985, "pin_cites": [ { "page": "672", "parenthetical": "holding that the trial court erred by allowing the plaintiff to present accident reconstruction evidence but precluding the defendant from presenting such evidence" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/130/0662-01" ] }, { "cite": "685 N.E.2d 1", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1996, "pin_cites": [ { "page": "10", "parenthetical": "the trial court has discretion to exclude evidence not directly related to the central issue of the case if the confusion of issues resulting from its admission would not be compensated for by its usefulness in the trial" }, { "page": "8", "parenthetical": "a party must state specific grounds for any objections, and other grounds not stated are waived on review" } ], "opinion_index": 0 }, { "cite": "291 Ill. App. 3d 635", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 456190 ], "weight": 2, "year": 1996, "pin_cites": [ { "page": "647-48", "parenthetical": "the trial court has discretion to exclude evidence not directly related to the central issue of the case if the confusion of issues resulting from its admission would not be compensated for by its usefulness in the trial" }, { "page": "645" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/291/0635-01" ] }, { "cite": "638 F.2d 270", "category": "reporters:federal", "reporter": "F.2d", "case_ids": [ 1357611 ], "year": 1981, "pin_cites": [ { "page": "277" } ], "opinion_index": 0, "case_paths": [ "/f2d/638/0270-01" ] }, { "cite": "847 F.2d 1261", "category": "reporters:federal", "reporter": "F.2d", "case_ids": [ 1778348 ], "year": 1988, "pin_cites": [ { "page": "1269" } ], "opinion_index": 0, "case_paths": [ "/f2d/847/1261-01" ] }, { "cite": "740 N.E.2d 9", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2000, "pin_cites": [ { "page": "18" } ], "opinion_index": 0 }, { "cite": "317 Ill. App. 3d 41", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1026067 ], "year": 2000, "pin_cites": [ { "page": "53" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/317/0041-01" ] }, { "cite": "706 N.E.2d 990", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1998, "pin_cites": [ { "page": "1001" } ], "opinion_index": 0 }, { "cite": "302 Ill. App. 3d 916", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1352881 ], "weight": 2, "year": 1998, "pin_cites": [ { "page": "929" }, { "page": "929" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/302/0916-01" ] }, { "cite": "726 N.E.2d 95", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 2000, "pin_cites": [ { "page": "105" }, { "page": "105" } ], "opinion_index": 0 }, { "cite": "312 Ill. App. 3d 11", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 411657 ], "weight": 2, "year": 2000, "pin_cites": [ { "page": "22-23" }, { "page": "22" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/312/0011-01" ] }, { "cite": "524 N.E.2d 939", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1988, "pin_cites": [ { "page": "944", "parenthetical": "concluding that the trial court's erroneous evidentiary ruling was harmless where the error related to an issue the jury never reached" }, { "page": "944", "parenthetical": "concluding that the trial court's erroneous evidentiary ruling was harmless where the error related to an issue the jury never reached" } ], "opinion_index": 0 }, { "cite": "170 Ill. App. 3d 505", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3584649 ], "weight": 2, "year": 1988, "pin_cites": [ { "page": "512", "parenthetical": "concluding that the trial court's erroneous evidentiary ruling was harmless where the error related to an issue the jury never reached" }, { "page": "512" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/170/0505-01" ] }, { "cite": "647 N.E.2d 618", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 3, "year": 1995, "pin_cites": [ { "page": "625" }, { "page": "625" }, { "page": "625", "parenthetical": "the burden is on the party seeking reversal to establish prejudice" } ], "opinion_index": 0 }, { "cite": "269 Ill. App. 3d 887", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 365852 ], "weight": 3, "year": 1995, "pin_cites": [ { "page": "895" }, { "page": "895" }, { "page": "895" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/269/0887-01" ] }, { "cite": "684 N.E.2d 1020", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1997, "pin_cites": [ { "page": "1024-25", "parenthetical": "physician was qualified to opine on the standard for informed consent, but not whether the plaintiff was actually informed" } ], "opinion_index": 0 }, { "cite": "291 Ill. App. 3d 795", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 456162 ], "year": 1997, "pin_cites": [ { "page": "801", "parenthetical": "physician was qualified to opine on the standard for informed consent, but not whether the plaintiff was actually informed" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/291/0795-01" ] }, { "cite": "498 N.E.2d 1167", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1986, "pin_cites": [ { "page": "1169", "parenthetical": "forensic pathologist's expertise did not extend to determining the ability of the defendant mother to feel her infant beneath her while asleep, despite the fact that he had a \"special interest\" in child abuse and had coauthored a paper on the topic" } ], "opinion_index": 0 }, { "cite": "147 Ill. App. 3d 272", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3604819 ], "year": 1986, "pin_cites": [ { "page": "275", "parenthetical": "forensic pathologist's expertise did not extend to determining the ability of the defendant mother to feel her infant beneath her while asleep, despite the fact that he had a \"special interest\" in child abuse and had coauthored a paper on the topic" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/147/0272-01" ] }, { "cite": "390 N.E.2d 1384", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1979, "pin_cites": [ { "page": "1390", "parenthetical": "if the jury is competent to determine the facts at issue, then the expert opinion is of no special assistance to the jury and should not be admitted" } ], "opinion_index": 0 }, { "cite": "73 Ill. App. 3d 74", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3260933 ], "year": 1979, "pin_cites": [ { "page": "83", "parenthetical": "if the jury is competent to determine the facts at issue, then the expert opinion is of no special assistance to the jury and should not be admitted" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/73/0074-01" ] }, { "cite": "574 N.E.2d 863", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1991, "pin_cites": [ { "page": "868", "parenthetical": "\"Expert testimony is improper when the inquiry regards an area within the common knowledge of the average juror\"" } ], "opinion_index": 0 }, { "cite": "215 Ill. App. 3d 104", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5293859 ], "year": 1991, "pin_cites": [ { "page": "112", "parenthetical": "\"Expert testimony is improper when the inquiry regards an area within the common knowledge of the average juror\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/215/0104-01" ] }, { "cite": "437 N.E.2d 376", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1982, "pin_cites": [ { "page": "382", "parenthetical": "\"In order to qualify as an expert, it must be shown that the proposed expert possesses special skills beyond the ken of the average juror and that he employed those skills in forming an opinion\"" } ], "opinion_index": 0 }, { "cite": "107 Ill. App. 3d 139", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3025879 ], "year": 1982, "pin_cites": [ { "page": "146", "parenthetical": "\"In order to qualify as an expert, it must be shown that the proposed expert possesses special skills beyond the ken of the average juror and that he employed those skills in forming an opinion\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/107/0139-01" ] }, { "cite": "696 N.E.2d 1271", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1998, "pin_cites": [ { "page": "1277" } ], "opinion_index": 0 }, { "cite": "297 Ill. App. 3d 165", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 910206 ], "year": 1998, "pin_cites": [ { "page": "174" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/297/0165-01" ] }, { "cite": "670 N.E.2d 721", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1996, "pin_cites": [ { "page": "730" } ], "opinion_index": 0 }, { "cite": "173 Ill. 2d 167", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 147606 ], "year": 1996, "pin_cites": [ { "page": "186" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/173/0167-01" ] }, { "cite": "558 N.E.2d 208", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1990, "opinion_index": 0 }, { "cite": "200 Ill. App. 3d 474", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2462919 ], "weight": 2, "year": 1990, "pin_cites": [ { "page": "479" }, { "page": "479" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/200/0474-01" ] }, { "cite": "747 N.E.2d 1045", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 2001, "pin_cites": [ { "page": "1059", "parenthetical": "\" 'Preservation of a question for review requires an appropriate objection in the court below [citation], and failure to object constitutes waiver.' Williams-burg Village Owners' Ass'n v. Lauder Associates, 200 Ill. App. 3d 474, 479, 558 N.E.2d 208[, 210-11] (1990)\"" }, { "page": "1059" } ], "opinion_index": 0 }, { "cite": "321 Ill. App. 3d 733", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 132469 ], "weight": 2, "year": 2001, "pin_cites": [ { "page": "750" }, { "page": "750" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/321/0733-01" ] }, { "cite": "882 P.2d 747", "category": "reporters:state_regional", "reporter": "P.2d", "year": 1994, "pin_cites": [ { "page": "776", "parenthetical": "holding that the Frye standard did not apply where computer programs listing various characteristics of homicides were \"nothing more than sophisticated record-keeping systems\"" } ], "opinion_index": 0 }, { "cite": "125 Wash. 2d 24", "category": "reporters:state", "reporter": "Wash. 2d", "case_ids": [ 437110 ], "year": 1994, "pin_cites": [ { "page": "70", "parenthetical": "holding that the Frye standard did not apply where computer programs listing various characteristics of homicides were \"nothing more than sophisticated record-keeping systems\"" } ], "opinion_index": 0, "case_paths": [ "/wash-2d/125/0024-01" ] }, { "cite": "583 N.E.2d 515", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1991, "pin_cites": [ { "page": "519", "parenthetical": "an abuse of discretion occurs only where the trial court's decision is arbitrary, fanciful, or unreasonable or where no reasonable man would take the view adopted by the trial court" }, { "page": "519", "parenthetical": "discussing the abuse of discretion standard" } ], "opinion_index": 0 }, { "cite": "145 Ill. 2d 353", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5596242 ], "weight": 2, "year": 1991, "pin_cites": [ { "page": "364", "parenthetical": "an abuse of discretion occurs only where the trial court's decision is arbitrary, fanciful, or unreasonable or where no reasonable man would take the view adopted by the trial court" }, { "page": "364" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/145/0353-01" ] }, { "cite": "763 N.E.2d 720", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 5, "year": 2002, "pin_cites": [ { "page": "737" }, { "page": "736" }, { "page": "736" }, { "page": "734-35" }, { "page": "736", "parenthetical": "jury's questions regarding the purpose and necessity of answering a special interrogatory did not display confusion on the jury's part" } ], "opinion_index": 0 }, { "cite": "198 Ill. 2d 541", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 29951 ], "weight": 5, "year": 2002, "pin_cites": [ { "page": "568" }, { "page": "566-67" }, { "page": "566-67" }, { "page": "563" }, { "page": "566" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/198/0541-01" ] }, { "cite": "701 N.E.2d 1107", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1998, "pin_cites": [ { "page": "1114" } ], "opinion_index": 0 }, { "cite": "296 Ill. App. 3d 416", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 222646 ], "year": 1998, "pin_cites": [ { "page": "427" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/296/0416-01" ] }, { "cite": "767 N.E.2d 314", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 3, "year": 2002, "pin_cites": [ { "page": "325-26" }, { "page": "323-24" }, { "page": "324" } ], "opinion_index": 0 }, { "cite": "199 Ill. 2d 63", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 58941 ], "weight": 3, "year": 2002, "pin_cites": [ { "page": "80-81" }, { "page": "76-78" }, { "page": "78" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/199/0063-01" ] }, { "cite": "706 N.E.2d 55", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 4, "year": 1999, "pin_cites": [ { "page": "60-65" }, { "page": "60-65" }, { "page": "62", "parenthetical": "\"If the scientific evidence is not 'novel,' then the Frye admissibility standard has been satisfied ***\"" }, { "page": "65" } ], "opinion_index": 0 }, { "cite": "302 Ill. App. 3d 364", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1352857 ], "weight": 4, "year": 1999, "pin_cites": [ { "page": "368-75" }, { "page": "368-75" }, { "page": "372" }, { "page": "376" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/302/0364-01" ] }, { "cite": "293 F. 1013", "category": "reporters:federal", "reporter": "F.", "case_ids": [ 11720199 ], "weight": 5, "year": 1923, "pin_cites": [ { "page": "1014" }, { "page": "1014" }, { "page": "1014", "parenthetical": "'[J]ust when a scientific principle or discovery crosses the line between the experimental and demonstrable stages is difficult to define. Somewhere in this twilight zone the evidential force of the principle must be recognized'" } ], "opinion_index": 0, "case_paths": [ "/f/293/1013-01" ] } ], "analysis": { "cardinality": 2874, "char_count": 116936, "ocr_confidence": 0.8, "pagerank": { "raw": 2.5045838436467854e-07, "percentile": 0.8098829313987032 }, "sha256": "ee59f8d23639c42973603f21eb74fd665d06871ff70b253db70527e2489ecf25", "simhash": "1:afaeb0d476ceb8f6", "word_count": 18639 }, "last_updated": "2023-07-14T19:45:54.915644+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [ "APPLETON, J., concurs." ], "parties": [ "DEBRA L. BACHMAN, as Mother and Legal Guardian of the Estate and Person of Danielle L. Bachman, a Disabled Person, et al., Plaintiffs-Appellants, v. GENERAL MOTORS CORPORATION et al., Defendants-Appellees." ], "opinions": [ { "text": "JUSTICE STEIGMANN\ndelivered the opinion of the court:\nIn December 2000, plaintiffs, Debra L. Bachman and Danielle L. Bachman, filed a third-amended complaint against defendants, General Motors Corporation (General Motors), Uftring Chevrolet-Oldsmobile, Inc. (Uftring), Delphi Automotive Systems (Delphi), and Delco Electronic Systems (Delco), seeking to recover for injuries Danielle sustained when her 1996 Chevrolet Cavalier collided with an oncoming 1984 Ford one-ton delivery van (step van). Plaintiffs alleged that the Cavalier\u2019s supplemental inflatable restraint system (air bag) inadvertently deployed prior to the collision, thus causing the collision. Later that same month, following a jury trial, the jury returned a verdict in favor of defendants and against plaintiffs.\nPlaintiffs appeal, arguing that (1) the trial court erred by (a) allowing evidence regarding data downloaded from the Cavalier\u2019s sensing and diagnostic module (SDM or SDM-R) (the air-bag crash sensor) and admitting related opinion testimony, (b) striking the causation opinion of one of plaintiffs\u2019 expert witnesses, (c) limiting the testimony of certain witnesses involved in allegedly similar occurrences, (d) allowing evidence regarding data downloaded from the SDMs of the vehicles that were driven by the \u201csimilar occurrence\u201d witnesses, (e) denying plaintiffs\u2019 motion to bar defendants\u2019 opinion witnesses based on alleged discovery violations, (f) permitting the jury to view Danielle\u2019s damaged Cavalier during defendants\u2019 case in chief, (g) allowing one of defendants\u2019 witnesses to testify about the dangerousness of the curve where Danielle\u2019s collision occurred, (h) allowing evidence regarding Danielle\u2019s seat belt use and the condition of her seat belt following the collision, (i) submitting a special interrogatory to the jury, and (j) denying plaintiffs\u2019 motion to amend their complaint to add a punitive damages prayer, pursuant to section 2 \u2014 604.1 of the Code of Civil Procedure (Code) (735 ILCS 5/2 \u2014 604.1 (West 1996)); (2) the jury\u2019s verdict was against the manifest weight of the evidence; and (3) the trial court\u2019s cumulative errors denied plaintiffs a fair trial. We affirm.\nI. BACKGROUND\nIn late October 1996, Danielle purchased a new 1996 Cavalier from Uftring. On the morning of November 6, 1996, Danielle was driving her Cavalier north on Nofsinger Road in Woodford County. At around 7:45 a.m., Danielle lost control of the car and collided with an oncoming step van. As a result of the collision, Danielle sustained very serious and permanently disabling injuries.\nIn June 1998, plaintiffs sued defendants (as well as other entities that are no longer parties to this action) for injuries Danielle sustained in the collision. In December 2000, plaintiffs filed a third-amended complaint, alleging as follows: (1) the air bag in Danielle\u2019s Cavalier, which was sold by General Motors through its authorized dealer, Uftring, was defective in that it inadvertently deployed because its SDM (which was designed and manufactured by Delphi and Delco) was \u201chypersensitive\u201d to road surfaces and objects striking the Cavalier\u2019s floor pan; (2) General Motors, alone and by and through Uftring, failed to warn consumers about defective air bags in 1996 Cavaliers; (3) negligence on the part of General Motors and Uftring; (4) Delphi and Delco failed to warn consumers about the defective air bags in 1996 Cavaliers; and (5) negligence on the part of Delphi and Delco.\nA. Frye Hearing\nIn September 2000, plaintiffs filed a motion in limine, seeking to bar defendants from presenting evidence regarding data downloaded from the SDM in Danielle\u2019s Cavalier. In October 2000, defendants filed a supplemental response to plaintiffs\u2019 motion, requesting a Frye hearing (see Frye v. United States, 293 F. 1013 (D.C. Cir. 1923)) to determine the admissibility of the SDM evidence. The trial court granted defendants\u2019 request, and the evidence at the November 2000 hearing showed the following.\nDouglas Nunan, a senior project engineer in Delphi\u2019s restraint systems electronics group, testified that between August 1989 and May 1996, he was responsible for designing and developing SDMs, including the type of SDM installed in Danielle\u2019s Cavalier. Crash sensing devices like the SDM are commonly used throughout the automobile industry. The SDM, which is controlled by a microprocessor, has multiple functions: (1) it determines if a severe enough impact has occurred to warrant deployment of the air bag; (2) it monitors the air bag\u2019s components; and (3) it permanently records information. The SDM contains software that analyzes the longitudinal deceleration of a vehicle to determine whether a deployment event has occurred \u201cbased on testing that was done previously to determine what events would require protection by an air bag.\u201d When the SDM senses an event (either a deployment event or an event that is not severe enough to require an air bag \u2014 that is, a near-deployment event), that information is recorded to the microprocessor\u2019s electrically erasable programmable read-only memory (EEPROM). (When the air bag is deployed, the SDM records the event as a \u201cCode 51.\u201d) Nunan explained that by recording data, \u201cyou have a record to go back and look to see, did the result that came out match what you should have had.\u201d Although certain diagnostic codes stored in the EEPROM could be erased, the SDM installed in the Cavalier \u201cwas specifically designed to prevent\u201d air-bag deployment data from being altered or erased.\nBased on crash test data, Nunan opined that the type of SDM installed in Danielle\u2019s Cavalier accurately and reliably recorded data. Because SDM data is stored in hexadecimal format, it must ordinarily be converted to a decimal format before it can be analyzed. (A hexadecimal system is a numbering system that has 16 characters; that system employs the letters A through F, in addition to the numbers zero through nine, which are used in the decimal system.) A competent engineer could convert and read the data using a basic calculator and General Motors documents. In mid-2000, a publicly available crash data retrieval tool (Vetronix equipment) was updated with new software to allow anyone with a Windows-based computer to download SDM data in an easy-to-read format. Based on Nunan\u2019s experience, engineers at the National Highway Traffic Safety Administration (NHTSA), as well as automobile manufacturing engineers, rely upon data that is recorded and stored by SDM-type devices. He opined that deployment and crash event data recorded by the SDM is generally accepted as reliable and accurate by the automobile industry and the NHTSA.\nNunan also stated that a power loss during a crash would not affect data previously recorded. Therefore, the fact that Danielle\u2019s Cavalier lost electrical power during the collision did not affect the reliability or accuracy of the data recorded by the SDM. Due to the Cavalier\u2019s loss of electrical power, an external power source was used to retrieve data from the SDM in August 1997. According to Nunan, such a procedure is normal and does not affect the accuracy of the SDM\u2019s data. Nunan further stated that the newly updated Vetronix equipment could be used to retrieve data from Danielle\u2019s Cavalier, and that data would be identical to the data originally retrieved. He acknowledged that the SDM\u2019s performance specifications were not public knowledge. He also acknowledged that at the time of the collision, crash data recorders in vehicles were not standardized.\nNunan further testified that General Motors began receiving reports in 1996 indicating that air bags in some Cavaliers and other \u201cJ-cars\u201d inadvertently deployed when small road objects hit a specific area under the car and the SDM\u2019s microprocessor incorrectly interpreted the incident as a deployment event. (J-cars included Cavaliers and Pontiac Sunfires.) General Motors\u2019 investigation of those inadvertent, non-crash deployments reconfirmed the reliability of the SDM\u2019s data-recording capabilities. Nunan explained that the eventual recall involved repairing the SDMs by recalibrating the software to create a higher threshold for air-bag deployment. However, that recalibration did not have anything to do with the SDM\u2019s data-recording function or the reliability of its recorded data. He also stated that in the reported inadvertent, non-crash deployment events, the SDMs recorded only a small change in velocity (delta-v or delta-velocity) or deceleration of the vehicles.\nJohn Sprague, a Delphi systems engineer who worked at General Motors in Warren, Michigan, testified that from 1993 through 1996, he was a sensing application engineer for several vehicles, including the 1996 Cavalier. He conducted development testing of the SDM and investigated actual field deployments. The SDM on the 1996 Cavalier was designed to sense longitudinal deceleration of the vehicle. A competent and knowledgeable engineer could convert and read the SDM data using General Motors documents and a basic calculator. He acknowledged that the 1996 Cavalier SDM\u2019s product definition documents were \u201cgenerally treated as confidential\u201d by General Motors.\nSprague also stated that he was involved in the investigation of the inadvertent-deployment cases. That investigation included downloading and reading data from (1) SDMs involved in the inadvertent deployments and (2) SDMs in vehicles used to replicate the actual inadvertent deployments. That data showed a relatively low delta-v, ranging from one to three miles per hour. The investigation also showed that when the vehicle\u2019s floor pan was hit in a particular manner, it caused a high frequency resonance that the SDM interpreted as a deployment event. The SDM\u2019s microprocessor correctly measured and performed calculations with the input signal, and using a deployment logic algorithm, the SDM compared the calculated values to calibration parameters programmed into the SDM. The SDM accurately recorded the delta-v as calculated by the SDM\u2019s microprocessor. However, the SDM made a decision to deploy the air bag when it was not actually needed.\nSprague opined that neither the defect nor the recall had anything to do with the SDM\u2019s recording function, the retrieval of data from the SDM, or the reliability of its recorded data. General Motors submitted information regarding the investigation to the NHTSA, which must approve the determination and proposed correction of an automobile defect. According to Sprague, no one from NHTSA ever questioned the reliability or accuracy of the data being downloaded from the 1996 J-cars. Based upon his development testing of the SDM and his investigation of the inadvertent-deployment events, Sprague opined that the SDM\u2019s recording function was both reliable and accurate.\nSprague further testified that the data retrieved from Danielle\u2019s Cavalier showed a delta-v of 16.2 miles per hour, which was above the air-bag deployment threshold and consistent with a crash event: He opined that the data retrieved from Danielle\u2019s Cavalier was not consistent with the data retrieved from the vehicles involved in the inadvertent-deployment events.\nThe trial court also considered several affidavits and documents submitted by the parties. Donald Floyd, a former supervisor of diagnostic software activities at General Motors, averred that he was responsible for releasing data to Vetronix for its use in developing a crash retrieval system for General Motors cars. The Vetronix equipment allows anyone with a computer equipped with Windows 95 or 98 to download data recorded by SDMs on General Motors vehicles. Floyd participated in testing with Vetronix, the Insurance Institute for Highway Safety, and Canadian law enforcement, in which the accuracy of downloaded SDM data was confirmed.\nDaniel Faust, a General Motors staff development engineer, averred that the NHTSA and the National Transportation Safety Board (NTSB) have requested other downloaded SDM collision data from General Motors. Keith Schultz, a General Motors senior staff engineer, averred that other government and law enforcement agencies also request and rely on SDM collision data downloaded by General Motors engineers. Schultz and NHTSA representatives coauthored an article entitled \u201cRecording Automotive Crash Event Data,\u201d in which they (1) concluded that the loss of electrical power during a crash did not affect the reliability or accuracy of data retrieved from the SDM and (2) suggested traffic safety uses for the SDM data.\nAfter considering the evidence and counsel\u2019s arguments, the trial court denied plaintiffs\u2019 motion in limine, upon determining that the data downloaded from the SDM in Danielle\u2019s Cavalier and opinions regarding that data were admissible at trial under both (1) the Frye standard (Frye, 293 F. at 1014); and (2) the \u201cFrye-plus-reliability\u201d standard set forth by this court in Harris v. Cropmate Co., 302 Ill. App. 3d 364, 368-75, 706 N.E.2d 55, 60-65 (1999).\nB. The Trial\nAt the November and December 2000 jury trial, Danielle testified that on October 28, 1996, she purchased a 1996 Cavalier from Uftring. When Danielle, who is 5 feet tall, drove her car, her seat was positioned close to the steering wheel, in an upright position. Around 7:15 a.m. on November 6, 1996, she left her house and drove toward Wesley Schalk\u2019s house on Nofsinger Road. About one-half mile from Schalk\u2019s house, the road had a rough section leading into a curve. That morning, she was driving between 35 and 40 miles per hour on that section of road when \u201cout of the blue [her] air bag unexpectedly deployed.\u201d The air bag knocked her hands off the steering wheel, hit her head, and rendered her unconscious, causing her to lose control of her car. She did not remember anything else about the collision.\nDanielle also testified that prior to the collision, neither Uftring nor General Motors warned her that a greater risk of inadvertent airbag deployment existed in 1996 Cavaliers. She acknowledged that during her discovery deposition, she testified that after the air bag deployed, she tried to unbuckle her seat belt and jump out of her car.\nJames Reed testified that around 8 a.m. on November 6, 1996, he was driving a 1984 Ford one-ton step van south on Nofsinger Road, which is a two-lane, tar and chip road. According to Reed, no loose gravel was on the road. As he was driving around a curve, Danielle\u2019s car \u201cstarted crossing the line\u201d and coming toward him. He acknowledged that during his deposition, he testified that Danielle was traveling too fast for the curve she was approaching. According to Reed, \u201c[i]t looked like she might have gotten control of [her car] and hit the dirt and then she [came] at [him] sidewise.\u201d Reed put on his brakes, steered toward the right, and was almost completely stopped when the front driver\u2019s side of Danielle\u2019s car hit his step van. Danielle\u2019s car did not slow down significantly prior to the collision. Reed did not see smoke inside Danielle\u2019s car as it was coming toward him, nor did he see anything inside her car at the time of the collision. Following the collision, Reed entered the passenger\u2019s side of Danielle\u2019s car and noticed that the driver\u2019s-side air bag had deployed.\nRichard A. Schneider, an Uftring auto body technician, testified that on the morning of November 6, 1996, he was driving behind Reed on Nofsinger Road. Nofsinger Road is \u201ca blacktop surface road that proceeds straight for some time, and *** has a series of gradual S-curves with a dip in the area where the accident occurred.\u201d The road has several bumps south of the collision scene; however, those bumps had never affected Schneider\u2019s ability to control his car when driving between 35 and 50 miles per hour. When he first noticed Danielle\u2019s car, she was traveling north around a curve on Nofsinger Road. Schneider estimated that Danielle was going \u201csignificantly more\u201d than the posted 35-mile-per-hour speed limit. Schneider saw Danielle\u2019s car fishtail to the left, with the back end of her car crossing the centerline into the southbound lane, then back to the right, and then back to the left again. At the time of the collision, the front of Danielle\u2019s car was pointing in a northeastern direction. According to Schneider, the left front portion of Reed\u2019s step van collided with the \u201crear of the left front fender\u201d and the left rear quarter panel of Danielle\u2019s car. He acknowledged that during his discovery deposition, he testified that Reed\u2019s step van hit Danielle\u2019s car at a right angle. At the time of the collision, Schneider did not see smoke inside Danielle\u2019s car or the air bags deploy. As he approached Danielle\u2019s car following the collision, he smelled the odor of deployed air bags and saw that both air bags had deployed and Danielle was wearing a seat belt.\nDaniel Law, an Illinois State Police sergeant, testified that at around 7:50 a.m. on November 6, 1996, he arrived at the scene of the collision. After observing Danielle, Law requested Life Flight, an emergency helicopter. He noted that the surface of Nofsinger Road was dry that morning. Based on Law\u2019s background as an accident investigator and his inspection of the scene, he concluded that Danielle\u2019s speed was a contributing cause of the collision. Law acknowledged that he did not calculate Danielle\u2019s speed at the moment of the collision.\nWilliam Gray, Jr., testified that at the time of the collision, he had lived on Nofsinger Road for about eight years and had driven on the road many times. Approximately 300 feet south of the collision site, the road\u2019s surface was \u201cwavy [and] ripply.\u201d When he drove over that section of the road, his vehicle bounced and vibrated \u201ca little bit.\u201d William stated that on the morning of November 6, 1996, Nofsinger Road was damp.\nRicki Gray testified that at the time of the collision, she had lived on Nofsinger Road for about seven years. When driving her car around the curve near the \u201crippled\u201d section of the road, it gave her the \u201cfeeling that [she] want[ed] to lose control.\u201d\nSeveral physicians, including Dr. Ronald Meyer, Danielle\u2019s treating physician, Dr. Panna Goswami, a rehabilitation physician, and Dr. Jai Kumar, a neurologist, testified about Danielle\u2019s various injuries and their treatment of her following the accident.\nJohn Sonye, Jr., General Motors\u2019 director of product investigations for North America, testified as an adverse witness that he participated in field performance evaluations of General Motors products. He participated in the investigation into claims of inadvertent air-bag deployments in 1996 and 1997 J-cars (referred to as the \u201c1241 investigation\u201d). Based upon that investigation, General Motors recalibrated the air-bag software to create a higher threshold for air-bag deployment. Sonye also stated that when the SDM commands an airbag deployment, it records the event as a Code 51. In some of the 1996 and 1997 Cavaliers that Sonye investigated, the SDM showed a Code 51 although no crash had occurred, which meant that the air bag had inadvertently deployed.\nSonye then identified plaintiffs\u2019 exhibit No. 7, an August 1998 recall letter from General Motors to its customers, which stated that (1) \u201cGeneral Motors [had] decided there [was] a defect related to motor vehicle safety in 1996 and some 1997 Chevrolet model vehicles\u201d; and (2) \u201c[b]ecause of certain calibrations in the air bag\u2019s computer, there [was] an increased risk of an air[-]bag deployment in a low speed crash or when an object strikes the floor pan.\u201d He acknowledged that the recall letter, which was the only notice sent to customers, also advised customers that their Chevrolet dealers would reprogram their SDMs at no charge to reduce the possibility of inadvertent deployments. He also identified plaintiffs\u2019 exhibit No. 28, an August 1998 product recall campaign bulletin, which stated that General Motors had determined that a defect \u201crelated to motor vehicle safety\u201d existed.\nSonye further testified that the 1241 investigation, which was in its \u201cinfancy stage\u201d in November 1996, ultimately showed that when the Cavalier\u2019s floor pan was hit in a particular manner with a force equivalent to a three- to five-ounce hammer, it caused an air-bag deployment. In those instances, the data recorded by the SDM showed a delta-v of less than five miles per hour, which \u201cwas clearly below the threshold at which it should have deployed.\u201d Sonye further stated that the data retrieved from the SDMs was reliable and was used to identify the inadvertent-deployment problem. He explained that the SDM accurately recorded data; however, it incorrectly interpreted that data as a crash. Once data is recorded by the SDM, it cannot be altered or erased, and a power loss during a crash would not affect data previously recorded.\nSprague testified as an adverse witness that Delphi designed and manufactured the SDM that was installed in 1996 and 1997 Cavaliers. He participated in the 1241 investigation, which showed that the inadvertent air-bag deployments occurred following short-duration events with \u201crelatively flat low [delta velocities] with little or no damage to the vehicles.\u201d The delta-v in the inadvertent air-bag deployments ranged from one to three miles per hour. Based on the 1241 investigation, the investigators changed the SDM\u2019s sensing calibration to increase the air-bag-deployment threshold. Sprague acknowledged that between October 1995 and August 1998, General Motors received approximately 200 complaints of inadvertent air-bag deployments. Around 24 complaints were filed prior to November 6, 1996.\nBrian Everest, a General Motors product analyst, testified as an adverse witness that he analyzed the performance of air bags during crashes involving General Motors vehicles. He participated in the August 4, 1997, joint inspection of Danielle\u2019s Cavalier. Everest visually inspected Danielle\u2019s car, but he did not inspect the car\u2019s undercarriage. He also downloaded data from the SDM using an event data retrieval unit (EDRU) that interfaces either with a vehicle\u2019s data link connector or directly to the SDM. Everest acknowledged that a person must receive some training to download data from an SDM. A copy of the downloaded data was provided to plaintiffs\u2019 attorney and their engineering expert. The SDM detects whether a vehicle\u2019s air bags should deploy, monitors the air bag\u2019s components, and permanently records information. The download from Danielle\u2019s SDM revealed only 160 to 170 milliseconds of data, although the SDM was capable of recording up to 300 milliseconds. Everest stated that a power loss likely caused the SDM to record only 160 to 170 milliseconds of data. He did not know what caused the power loss in Danielle\u2019s car.\nKeith Schultz, a senior staff engineer for General Motors\u2019 product investigations department, testified as an adverse witness that his department\u2019s primary role is to communicate with the federal government regarding problems with General Motors products. He stated that the tool that was used to download data from the SDM was not publicly available in 1996. At that time, a person would need certain General Motors documents to interpret the downloaded data. However, once provided with the proper documents, a competent engineer could interpret data downloaded from the SDM. General Motors provided the proper documents to plaintiffs\u2019 attorney and experts in this case. Sometime in 2000, a crash data retrieval tool that was designed to download and interpret SDM data was made available to the public.\nDennis McConnell, a General Motors customer assistance manager, testified that he assisted in the 1241 investigation. He identified plaintiffs\u2019 exhibit No. 68 as an August 22, 1996, customer complaint regarding a 1996 J-car\u2019s air bag that had deployed \u201cwith no impact.\u201d McConnell also identified plaintiffs\u2019 exhibit No. 67 as an October 30, 1995, customer complaint regarding a 1996 Cavalier\u2019s air bag that had deployed without impact. He stated that such customer complaints were kept in the regular course of business.\nDouglas Page, a mechanical engineer, testified as plaintiffs\u2019 expert witness that he had almost 35 years\u2019 experience in the aerospace industry, including work with the F-5 fighter plane and developing certain devices for the Gemini and Apollo space programs. Page acknowledged that he had never worked in the automobile industry or designed any type of air bag or SDM. Page did not have experience testing a recording system like the one on the SDM or retrieving crash event data from an automobile. However, he stated that based on his work in the aerospace industry, he understood the general principles of air-bag deployment. On August 4, 1997, Page conducted a joint inspection of Danielle\u2019s Cavalier, along with some General Motors inspectors. Page identified certain photographs, which showed damage to Danielle\u2019s car \u201cfrom just behind the front wheel\u201d on the driver\u2019s side to the rear left wheel. Following the visual inspection, the General Motors inspectors removed the SDM and downloaded its recorded data.\nPage also testified that he reviewed several items in formulating his opinions, including the following: (1) a printout of the downloaded data from the SDM removed from Danielle\u2019s Cavalier; (2) excerpts from the Cavalier\u2019s owner\u2019s manual and service manual regarding its air-bag system; (3) a videotape showing the accident scene and Reed\u2019s step van; (4) photographs of the step van; (5) correspondence between NHTSA and Sonye; (6) a \u201cnear deployment file worksheet\u201d; (7) a copy of the accident report; (8) several discovery depositions; and (9) certain General Motors and NHTSA documents.\nBased on his review of those items, Page opined that the SDMs installed in 1996 and some 1997 Cavaliers (1) were defective because they had an increased risk of inadvertent deployment and (2) had inadvertently deployed in over 200 cases. He also opined that the air bag in Danielle\u2019s Cavalier \u201cinadvertently deployed primarily due to design faults in the system.\u201d He based that opinion on (1) \u201can accumulation of information from throughout the General Motors documents\u201d; (2) Danielle\u2019s deposition testimony that the air bag inadvertently deployed; (3) Schneider\u2019s deposition testimony that he never saw Danielle\u2019s air bag deploy; and (4) Reed\u2019s deposition testimony that he saw Danielle\u2019s car fishtailing prior to the collision. Page also stated that the condition of Nofsinger Road (specifically, the bumpy, \u201cwashboard\u201d section and loose pebbles) could have caused the inadvertent deployment of Danielle\u2019s air bag.\nPage also opined that the air bag in Danielle\u2019s Cavalier was not designed to deploy on a side impact. He based that opinion on his review of (1) Cavalier\u2019s owner\u2019s and service manuals, and (2) deposition testimony. Page explained that the service manual stated that the air bag was designed to deploy when the car was involved in a \u201cfrontal crash up to 30 degrees off the center[ ]line of the vehicle.\u201d He further opined that the collision involved a \u201ct-bone\u201d side impact to Danielle\u2019s Cavalier, basing that opinion on his review of the photographs of her car following the collision. Page acknowledged that his opinion in this regard was \u201cat odds\u201d with plaintiffs\u2019 accident reconstruction expert, who opined that Reed\u2019s step van hit Danielle\u2019s car at a 43-degree angle.\nPage additionally opined that the data downloaded from the SDM in Danielle\u2019s car (1) was in a hexadecimal code, which was confidential and known only to General Motors, Delco, or Delphi, and (2) was not accurate or reliable. He stated that the algorithms and formulas were proprietary to General Motors and not subject to examination by him. He also stated that the SDM \u201ccan be lied to\u201d by its sensors. Although the SDM can record 300 milliseconds of data, the printout from Danielle\u2019s SDM contained only 170 milliseconds of data.\nPage acknowledged that he did not know exactly what caused Danielle\u2019s air bag to deploy. He also acknowledged that he did not inspect the site of the collision or Reed\u2019s step van. Page further stated that the SDM from Danielle\u2019s Cavalier recorded a longitudinal deceleration during the November 6, 1996, incident. The data downloaded from that SDM showed a delta-v of over 16 miles per hour, which exceeded the level at which the air bag was designed to deploy. The SDM recorded only one deployment event during the time Danielle was driving the Cavalier on the morning of November 6, 1996. Page additionally acknowledged that he did not rely on the data downloaded from the SDM in Danielle\u2019s car because he never attempted to interpret the data and \u201c[i]t was meaningless to [him].\u201d Nor had he compared the data downloaded from Danielle\u2019s SDM with the data downloaded from the Cavaliers that were part of the 1241 investigation. Page also conceded that he could not say that the SDM was inaccurate.\nRonald L. Van Daele, plaintiffs\u2019 accident reconstruction expert, testified that \u201c[t]he contact damage on the Cavalier [began] at the rear of the front left wheel, wheel well, and continue [ed] rearward, including the driver\u2019s door, the left side of the windshield, left side of the roof, the rear left quarter panel and ending in the center of the rear left wheel well.\u201d Van Daele opined that based on his reconstruction of the accident, Reed\u2019s step van hit Danielle\u2019s car at a 43-degree angle. He stated that the impact constituted a side impact, but not a \u201c90-degree, pure t-bone side impact.\u201d Van Daele also stated that the Cavalier\u2019s initial instability was due to the bumpy road surface. He further stated that \u201c[t]he allegation that the air bag inadvertently deployed causing [Danielle] to be stunned appears to be reasonable.\u201d He opined that (1) \u201c[t]he Cavalier appeared to be driven by a person who could have been stunned, but not certainly out of control\u201d; and (2) he could think of no other cause for Danielle\u2019s lack of reaction to the approaching hazard of Reed\u2019s step van. Van Daele additionally opined that if Danielle had attempted to negotiate the curve just south of the collision scene at a high rate of speed, she would have crashed into a nearby ravine, not Reed\u2019s step van. The only role speed played in the collision was its effect on the severity of the crash.\nVan Daele acknowledged that (1) the data downloaded from the SDM in Danielle\u2019s Cavalier showed a delta-v of over 16 miles per hour and (2) the Cavalier\u2019s collision with Reed\u2019s step van was the only thing that could have resulted in such a change in velocity.\nSeveral witnesses testified that they had been driving 1996 or 1997 J-cars when the driver\u2019s side air bag inadvertently and unexpectedly deployed. Those witnesses also testified that the air bag knocked their hands off the steering wheel and created noise and smoke upon deployment.\nSharon Seckler testified for defendants that on the morning of November 6, 1996, she was in her house when she heard a crash. She walked down her driveway and saw that a Cavalier and a step van had collided. Seckler looked inside Danielle\u2019s car and noticed that Danielle was wearing a seat belt and the air bag had deployed. Seckler stated that she had lived on Nofsinger Road for almost eight years and had frequently driven through the same curve Danielle had driven through just before the collision. Based on Seckler\u2019s personal experience, if a person drives around the curve at more than 35 miles per hour, that person could lose control and cross the centerline.\nAlan Thebert, a crash analysis automotive engineer, testified as defendants\u2019 accident reconstruction expert that when Reed\u2019s step van finally collided with the left rear wheel of Danielle\u2019s car, \u201cthe force between the two vehicles was almost purely front to rear.\u201d Thebert opined that Danielle was traveling at approximately 55 to 60 miles per hour as she drove through the curve approaching the collision site. He also opined that Danielle was driving 45 to 50 miles per hour when the collision occurred. Thebert further opined that (1) Reed\u2019s step van collided with Danielle\u2019s Cavalier at a 30- to 45-degree angle; and (2) as a result of the collision, the Cavalier experienced longitudinal deceleration. He additionally opined that (1) Danielle was steering the Cavalier as she came around the curve and up to the point of the collision and (2) the collision was due to driver error and excessive speed.\nEdward McKenna, a product litigation consultant, testified for defendants that in April 1999, he inspected the driver\u2019s seat belt assembly in Danielle\u2019s Cavalier. McKenna opined that (1) Danielle had worn the seat belt during the collision, (2) \u201cthe marks on the belt\u201d and latch plate showed that Danielle moved forward and to the left during the collision, and (3) \u201c[t]he seat belt restrain[ed] the forward motion when the longitudinal deceleration was being experienced by the car.\u201d\nNunan testified regarding the purposes, function, and accuracy of the SDM, as he did at the Frye hearing. He also stated that based on his review of a videotape of the downloading of the SDM data from Danielle\u2019s Cavalier, the downloading was performed properly. Nunan opined that the downloading process had no effect on the data downloaded from the SDM. The downloaded data showed that the delta-v for Danielle\u2019s Cavalier during the collision was 16.2 miles per hour, which was above the air-bag-deployment threshold of 14 miles per hour. In contrast, the data from the 1241 investigation showed that the delta-v in the inadvertent-deployment cases was one to two miles per hour.\nNunan also testified that the SDM can record two separate events in the same ignition cycle (measured each time the vehicle is started). Nunan stated that if \u2014 as plaintiffs alleged \u2014 Danielle\u2019s Cavalier experienced an inadvertent deployment prior to the collision, \u201cthere would be two records present in the SDM\u201d: (1) the inadvertent deployment; and (2) the 16.2-mile-per-hour delta-v. The SDM recorded only one event \u2014 the 16.2-mile-per-hour delta-v \u2014 during the November 6, 1996, ignition cycle. Nunan also opined that the air-bag-deployment threshold was exceeded when Danielle\u2019s Cavalier collided with Reed\u2019s step van. He further opined that (1) the loss of power to the Cavalier during the collision had no effect on the data recorded by the SDM, (2) the data downloaded from the Cavalier was inconsistent with the data downloaded from cars involved in the 1241 investigation, and (3) the air bag in Danielle\u2019s Cavalier did not inadvertently deploy.\nRoger Nightingale, a biomedical engineer, testified regarding the causes of Danielle\u2019s specific injuries. He opined that the overall cause of Danielle\u2019s injuries was the \u201coppressive\u201d intrusion of Reed\u2019s step van into the Cavalier.\nOn this evidence, the jury returned a verdict in favor of defendants and against plaintiffs. The jury also answered \u201cno\u201d to defendants\u2019 special interrogatory, which inquired as follows: \u201cDid the driver\u2019s side air bag inadvertently deploy on November 6, 1996?\u201d This appeal followed.\nII. ANALYSIS\nA. The Trial Court\u2019s Decision To Allow Evidence Regarding the Cavalier\u2019s SDM Data\nPlaintiffs first argue that the trial court erred by denying their motion in limine to exclude evidence regarding the data downloaded from the SDM in Danielle\u2019s Cavalier and related opinion testimony. We disagree.\nInitially we note that prior to oral argument in this case, the Supreme Court of Illinois in Donaldson v. Central Illinois Public Service Co., 199 Ill. 2d 63, 80-81, 767 N.E.2d 314, 325-26 (2002), clarified that the Frye standard is the standard in Illinois, not the \u201cFrye-plus-reliability\u201d standard (see Harris, 302 Ill. App. 3d at 368-75, 706 N.E.2d at 60-65). We thus determine whether the trial court abused its discretion by admitting SDM data and related testimony under the Frye standard.\n\u201cThe determination of whether a party has met the Frye standard lies within the trial court\u2019s discretion, and a reviewing court will not reverse absent an abuse of that discretion.\u201d First Midwest Trust Co. v. Rogers, 296 Ill. App. 3d 416, 427, 701 N.E.2d 1107, 1114 (1998). \u201cIn determining whether there has been an abuse of discretion, [a reviewing court] may not substitute [its] judgment for that of the trial court, or even determine whether the trial court exercised its discretion wisely.\u201d Simmons v. Garces, 198 Ill. 2d 541, 568, 763 N.E.2d 720, 737 (2002); see also People v. Illgen, 145 Ill. 2d 353, 364, 583 N.E.2d 515, 519 (1991) (an abuse of discretion occurs only where the trial court\u2019s decision is arbitrary, fanciful, or unreasonable or where no reasonable man would take the view adopted by the trial court).\nIn Donaldson, 199 Ill. 2d at 76-78, 767 N.E.2d at 323-24, the supreme court discussed the admission of expert testimony under the Frye standard, stating as follows:\n\u201cIllinois law is unequivocal: the exclusive test for the admission of expert testimony is governed by the standard first expressed in Frye v. United States, 293 F. 1013 (D.C. Cir. 1923). [Citations.] The Frye standard, commonly called the \u2018general acceptance\u2019 test, dictates that scientific evidence is only admissible at trial if the methodology or scientific principle upon which the opinion is based is \u2018sufficiently established to have gained general acceptance in the particular field in which it belongs.\u2019 Frye, 293 F. at 1014.\nFirst, \u2018general acceptance\u2019 does not concern the ultimate conclusion. Rather, the proper focus of the general acceptance test is on the underlying methodology used to generate the conclusion. If the underlying method[s] used to generate an expert\u2019s opinion are reasonably relied upon by the experts in the field, the fact finder may consider the opinion \u2014 despite the novelty of the conclusion rendered by the expert. [Citations.]\nSecond, general acceptance of methodologies does not mean \u2018universal\u2019 acceptance of methodologies. *** \u2018In determining whether a novel scientific procedure is \u201cgenerally accepted\u201d in the scientific community, the issue is consensus versus controversy over a particular technique. *** Moreover, the mere existence of a dispute does not preclude a finding that the procedure is generally accepted.\u2019 [Citations; see] Frye, 293 F. at 1014 (\u2018[J]ust when a scientific principle or discovery crosses the line between the experimental and demonstrable stages is difficult to define. Somewhere in this twilight zone the evidential force of the principle must be recognized\u2019). Simply stated, general acceptance does not require that the methodology be accepted by unanimity, consensus, or even a majority of the experts. A technique, however, is not \u2018generally accepted\u2019 if it is experimental or of dubious validity. Thus, the Frye rule is meant to exclude methods new to science that undeservedly create a perception of certainty when the basis for the evidence or opinion is actually invalid.\u201d\nIn denying plaintiffs\u2019 motion in limine to exclude evidence regarding the SDM data and related opinion testimony, the trial court initially found that the process of recording SDM data was not novel, stating as follows:\n\u201cComputer data, in general, and it is the computer information being recorded, in the court\u2019s mind[,] is not novel. It is an accepted fact of society. We have floppy disks, tape backups, [Z]ip drives used by individuals and businesses alike to record and capture data.\nThe microprocessor used in the SDM-R in this case is used in many consumer products and is a standard part used in various vehicle control systems, including engine controls, anti-lock brakes, suspension controls and air bags. It is only the admissibility, under the Frye test, of the SDM-R data which could be, in the court\u2019s opinion, conceived as novel.\u201d\nWe agree with the trial court that the process of recording and downloading SDM data does not appear to constitute a novel technique or method. See American Heritage Dictionary of the English Language 898 (1975) (defining \u201cnovel\u201d as \u201c[s]trikingly new, unusual, or different\u201d). Crash sensors such as the SDM have been in production in automobiles for over a decade, and the microprocessors that run them and record their data also run everyday appliances, such as computers and televisions. See Harris, 302 Ill. App. 3d at 372, 706 N.E.2d at 62 (\u201cIf the scientific evidence is not \u2018novel,\u2019 then the Frye admissibility standard has been satisfied ***\u201d); see also State v. Russell, 125 Wash. 2d 24, 70, 882 P.2d 747, 776 (1994) (holding that the Frye standard did not apply where computer programs listing various characteristics of homicides were \u201cnothing more than sophisticated record-keeping systems\u201d).\nNonetheless, because the admissibility of SDM data is a question of first impression, we analyze its admissibility under the Frye standard \u2014 as did the trial court. In determining that \u201c[t]he method of downloading data, and utilization of data recorded by the SDM\u201d was generally accepted within the relevant scientific community, the court stated, in pertinent part, as follows:\n\u201c[T]he court refers to the scientific community or communities as being mechanical engineering and/or physics.\nIs the technique or method generally accepted within that community? The defendants have offered affidavits of General Motors engineers and/or non[-General Motors] engineers, albeit engineers who are employed by the defendants.\nHave any physicists, mechanical engineers[,] and/or accident re-constructionist experts scrutinized that data outside [General Motors]? According to the documents which have been submitted to the court, [two individuals with NHTSA] coauthored an article with [General Motors] employees Tom Mercer and Keith Schultz entitled \u2018Recording Automotive Crash Event Data\u2019 in 1999 utilizing data captured by [General Motors] vehicles within that article.\nThat article suggested the three uses for data stored on these devices[:] [(]1) for improving air[-]bag sensing systems[;] [(]2) improving roadway design[; and] [(]3) developing meaningful motor vehicle regulations.\nIn essence, that data would be utilized for research and development purposes and/or for traffic[-]safety[-]related purposes.\nThe SDM data, from not only this particular vehicle but other SDMs, is now available to all researchers and investigators via the system created by the Vetronix Corporation of California.\nPrior to the release of the system, Vetronix verified the accuracy of the data recorded by the SDM.\nThe system is now being used, per the affidavit of Donald Floyd, by NHTSA, Transport Canada, Insurance Institute for Highway Safety, [and several state police departments], in addition to independent researchers and accident reconstructionists.\nPer the affidavit of Daniel Faust, an employee of [General Motors], the data recorded by [General Motors] SDMs has been requested by the [NTSB],\n* * *\nThe downloaded purported data utilized in determining how to change [the] calibration in the SDM-R was used to prevent inadvertent deployment of air bags.\nThe loss of electrical power during a crash event does not affect the reliability or accuracy of data written to memory prior to loss of power.\nThat the downloaded recorded data from the SDM-R has been compared with independent instrument grade accelerometers to verify delta-velocity values and were accurate.\nThat the data recording function of the SDM-R is separate from the deployment function of the SDM-R.\n* *\nThe SDM data, in addition, is currently subject to peer review via the software/hardware codeveloped with or by [General Motors] with Vetronix Corporation.\u201d\nReviewing the record before us under the appropriate standards, we conclude that the trial court did not abuse its discretion by (1) finding that the process of recording and downloading SDM data is sufficiently established to have gained general acceptance in the relevant scientific community, and, thus, (2) determining that the Frye admissibility standard had been satisfied. This process is simply not the sort of method \u201cnew to science that undeservedly create[s] a perception of certainty when the basis for the evidence or opinion is actually invalid\u201d (Donaldson, 199 Ill. 2d at 78, 767 N.E.2d at 324). Accordingly, we hold that the court did not err by allowing evidence regarding data downloaded from Danielle\u2019s SDM and related opinion testimony.\nIn so concluding, we reject plaintiffs\u2019 contention that the trial court \u201cerred in its finding of general acceptance within the scientific community\u201d because (1) the SDM data is \u201cproprietary and confidential\u201d and \u201cnot subject to any independent testing or verification analysis,\u201d (2) \u201cno uniformity in data recording or retrieval\u201d exists among automobile manufacturers, and (3) NHTSA meetings to discuss uniform standards are \u201cclosed to the public.\u201d Contrary to plaintiffs\u2019 contentions, the record shows that any competent engineer could interpret the SDM data using documents General Motors produced in discovery and a calculator. Further, (1) whether the workings of General Motors SDM are kept \u201cconfidential\u201d from competitors, (2) whether the SDM records data pursuant to uniform standards, and (3) whether NHTSA holds public meetings are not issues pertinent to determining whether the process of recording and downloading SDM data is generally accepted by the relevant scientific community.\nWe also reject plaintiffs\u2019 contention that the trial court \u201cerred in relying upon\u201d defendants\u2019 affidavits. Plaintiffs have forfeited this issue on appeal by advising the court that they had no objection to the court\u2019s considering defendants\u2019 affidavits. See Kotvan v. Kirk, 321 Ill. App. 3d 733, 750, 747 N.E.2d 1045, 1059 (2001) (\u201c \u2018Preservation of a question for review requires an appropriate objection in the court below [citation], and failure to object constitutes waiver.\u2019 Williams-burg Village Owners\u2019 Ass\u2019n v. Lauder Associates, 200 Ill. App. 3d 474, 479, 558 N.E.2d 208[, 210-11] (1990)\u201d). Further, \u201c[i]n conducting a Frye evidentiary hearing (as in any hearing to determine the admissibility of opinion testimony), the trial court is not required to strictly comply with the rules of evidence\u201d and may consider \u201ctestimony or affidavits of experts.\u201d Harris, 302 Ill. App. 3d at 376, 706 N.E.2d at 65.\nB. The Trial Court\u2019s Decision To Strike Page\u2019s Testimony on Causation\nPlaintiffs next argue that the trial court erred by striking Page\u2019s opinion testimony that the alleged inadvertent deployment of the air bag caused Danielle to lose control of her car and crash into Reed\u2019s step van (causation opinion). Specifically, they contend that the court\u2019s striking of Page\u2019s testimony on causation \u201cwas tantamount to directing a verdict for the [defendants and deprived the [p]laintiffs of a fair trial in this case.\u201d We disagree.\nIn People v. Miller, 173 Ill. 2d 167, 186, 670 N.E.2d 721, 730 (1996), the supreme court discussed the applicable law regarding expert witnesses, stating as follows:\n\u201cWhether an individual is an expert on a particular subject is a matter generally reserved to the sound discretion of the trial court. [Citation.] An individual will be allowed to testify as an expert if his experience and qualifications afford him knowledge which is not common to laypersons, and where such testimony will aid the trier of fact in reaching its conclusions. [Citation.] An expert need only have knowledge and experience beyond that of the average citizen.\u201d\nIn addition, in Kleiss v. Cassida, 297 Ill. App. 3d 165, 174, 696 N.E.2d 1271, 1277 (1998), this court stated as follows:\n\u201cThe trial court has a special responsibility as to expert witnesses. The decision whether to admit expert testimony, both whether the expert is qualified and whether his testimony will assist the trier of fact in understanding the evidence, rests within the sound discretion of the trial court.\u201d\nSee also Galindo v. Riddell, Inc., 107 Ill. App. 3d 139, 146, 437 N.E.2d 376, 382 (1982) (\u201cIn order to qualify as an expert, it must be shown that the proposed expert possesses special skills beyond the ken of the average juror and that he employed those skills in forming an opinion\u201d).\nIn October 2000, defendants filed a motion in limine, seeking to preclude Page\u2019s testimony on the grounds that (1) Page did not possess adequate qualifications, and (2) his opinions were not \u201csupported by reliable analysis.\u201d Following a November 2000 hearing, the trial court denied that motion. Defendants renewed their motion immediately prior to Page\u2019s direct testimony, arguing that Page \u201cignore[d] the SDM data, [and had] only three bases for his opinions,\u201d the deposition testimony of Danielle, Schneider, and Reed. The court noted for the record that defendants had made their objections and reaffirmed its prior ruling.\nDuring his direct testimony, Page opined that the inadvertent deployment of the air bag in Danielle\u2019s Cavalier caused her to lose control of the car and crash into Reed\u2019s step van. When plaintiffs\u2019 counsel asked Page the basis for his causation opinion, he stated, \u201cWell, once again, I have to go back to the three witnesses that have given deposition[s] in this particular instance. And that is Danielle Bachman herself, and *** Mr. Reed, and Mr. Schneider.\u201d When counsel then asked Page what he had gleaned from those depositions, he stated, in pertinent part, as follows:\n\u201cWell, specifically, Danielle Bachman asserts that the air bag inflated without any particular reason and knocked her hands clear of the steering wheel. ***\nAnd then she also states that \u2014 her exact words was [sic] \u2018freaking out.\u2019 She was trying to get out of a moving automobile. She was trying to unbuckle her seat belt.\nThen there is [sic] the other two witnesses that state that the car was fishtailing.\nThis all leads me to believe that she had little, if any, control over the automobile.\u201d\nFollowing Page\u2019s testimony, the trial court sua sponte reconsidered defendants\u2019 motion to preclude Page\u2019s testimony with respect to his causation opinion. The court found that (1) Page had \u201cindicated no engineering basis for his testimony\u201d; (2) his causation opinion was based \u201csolely on the depositions of the three witnesses\u201d; (3) Page had disavowed his deposition testimony that his causation opinion was based, in some unspecified way, on General Motors documents; (4) \u201chis testimony did not tie up in any way, shape or form to any [General Motors] documents\u201d; (5) \u201cin essence, what he offered was solely lay opinion concerning whether or not driver error caused [Danielle] to lose control\u201d; and (6) in reaching his causation opinion, Page \u201cdid not employ knowledge and application of principles of science beyond the ken of the average juror.\u201d The court thus instructed the jury to disregard Page\u2019s causation opinion. The court further stated that the jury \u201cmay and will consider the six other opinions that [Page] testified to,\u201d including his opinion that the air bag in Danielle\u2019s Cavalier inadvertently deployed.\nWe conclude that the trial court did not abuse its discretion by determining that Page \u201cdid not employ knowledge and application of principles of science beyond the ken of the average juror\u201d in reaching his opinion that the alleged inadvertent deployment of the air bag caused Danielle to lose control of her car and crash into Reed\u2019s step van. Page essentially recapitulated the deposition testimony of Danielle (some of which she repudiated at trial), Reed, and Schneider. The jury was clearly able to assess and draw inferences from the testimony of those witnesses without Page\u2019s expert testimony. Simply put, a jury does not need expert testimony to help it decide whether an inadvertently deployed air bag might cause a driver to lose control of her car. See Coyne v. Robert H. Anderson & Associates, Inc., 215 Ill. App. 3d 104, 112, 574 N.E.2d 863, 868 (1991) (\u201cExpert testimony is improper when the inquiry regards an area within the common knowledge of the average juror\u201d); see also Harvey v. Norfolk & Western Ry. Co., 73 Ill. App. 3d 74, 83, 390 N.E.2d 1384, 1390 (1979) (if the jury is competent to determine the facts at issue, then the expert opinion is of no special assistance to the jury and should not be admitted).\nIn addition, nothing in the record shows that Page\u2019s expertise extended to determining whether an inadvertent air-bag deployment caused Danielle to lose control of her Cavalier and crash into Reed\u2019s step van. Page was a mechanical engineer with almost 35 years\u2019 experience in the aerospace industry. However, he had no prior experience in the automobile industry or with air bags, and he professed no expertise in accident reconstruction or the effects of air-bag deployments on drivers. Page\u2019s qualifications simply did not enable him to form an opinion as to the cause of Danielle\u2019s collision. See, for example, People v. Perry, 147 Ill. App. 3d 272, 275, 498 N.E.2d 1167, 1169 (1986) (forensic pathologist\u2019s expertise did not extend to determining the ability of the defendant mother to feel her infant beneath her while asleep, despite the fact that he had a \u201cspecial interest\u201d in child abuse and had coauthored a paper on the topic); Grant v. Petroff, 291 Ill. App. 3d 795, 801, 684 N.E.2d 1020, 1024-25 (1997) (physician was qualified to opine on the standard for informed consent, but not whether the plaintiff was actually informed).\nMoreover, even accepting plaintiffs\u2019 contention that the trial court erred by striking Page\u2019s testimony on causation, we conclude that such error was harmless. A reviewing court will grant reversal based on evidentiary rulings only when the error was substantially prejudicial and affected the outcome of the trial. Conversely, where it appears that an error did not affect the outcome of the trial, or where the reviewing court can see from the entire record that the error did not result in substantial prejudice, the judgment will not be disturbed. Simmons, 198 Ill. 2d at 566-67, 763 N.E.2d at 736. The burden is on the party seeking reversal to establish prejudice. Halleck v. Coastal Building Maintenance Co., 269 Ill. App. 3d 887, 895, 647 N.E.2d 618, 625 (1995).\nPlaintiffs claim the trial court\u2019s exclusion of Page\u2019s testimony on causation was \u201cdevastating\u201d because he was their \u201conly liability expert.\u201d However, the court did not strike Page\u2019s opinion that the air bag in Danielle\u2019s Cavalier inadvertently deployed. In addition, Van Daele, plaintiffs\u2019 accident reconstruction expert, opined that (1) \u201c[t]he Cavalier appeared to be driven by a person who could have been stunned\u201d by an inadvertent air-bag deployment and (2) he \u201ccould think of no other cause for Danielle\u2019s lack of reaction to the approaching hazard of Reed\u2019s van.\u201d Further, the excluded evidence related to whether the inadvertent deployment of Danielle\u2019s air bag caused her to lose control of the Cavalier and collide with Reed\u2019s step van. However, the jury explicitly found that Danielle\u2019s air bag did not inadvertently deploy. Thus, the jury did not reach the issue of causation. Accordingly, because the error related to the causation issue, which was never reached by the jury, that error was harmless. See Cairns v. Hansen, 170 Ill. App. 3d 505, 512, 524 N.E.2d 939, 944 (1988) (concluding that the trial court\u2019s erroneous evidentiary ruling was harmless where the error related to an issue the jury never reached).\nC. The Trial Court\u2019s Decision To Limit the Testimony of Similar-Occurrence Witnesses\nPlaintiffs next argue that the trial court erred by prohibiting plaintiffs\u2019 similar-occurrence witnesses from testifying that when the driver\u2019s-side air bags on their 1996 and 1997 J-cars inadvertently deployed, the air bags struck them and, in some cases, caused them to lose control of their cars. We disagree.\nEvidence of prior occurrences or accidents may be admissible if relevant to the proponent\u2019s case. Generally, a prior occurrence is relevant to show (1) the existence of a particular danger or hazard or (2) the defendant\u2019s notice of the generally hazardous nature of the accident site. A plaintiff is required to lay a foundation of substantial similarity between the prior and present accidents if the plaintiff offers the prior accident evidence to show a particular hazard or danger. Mikus v. Norfolk & Western Ry. Co., 312 Ill. App. 3d 11, 22-23, 726 N.E.2d 95, 105 (2000). The determination whether prior occurrences or accidents are substantially similar to the one at issue lies within the trial court\u2019s sound discretion. Sobczak v. Flaska, 302 Ill. App. 3d 916, 929, 706 N.E.2d 990, 1001 (1998). Even if evidence is arguably relevant, the trial court may still exclude the evidence if it would confuse the issues or tend to mislead the jury. Demos v. Ferris-Shell Oil Co., 317 Ill. App. 3d 41, 53, 740 N.E.2d 9, 18 (2000). As the Seventh Circuit Court of Appeals wrote in Nachtsheim v. Beech Aircraft Corp., 847 F.2d 1261, 1269 (7th Cir. 1988):\n\u201cAs the circumstances and conditions of the other accidents become less similar to the accident under consideration, the probative force of such evidence decreases. At the same time, the danger that the evidence will be unfairly prejudicial remains. *** In addition, the costs \u2014 in terms of time, distraction and, possibly, prejudice \u2014 resulting from such evidence also may weigh against its admissibility. Accordingly, \u2018[e]ven when substantial identity of the circumstances is proven, the admissibility of such evidence lies within the discretion of the trial judge who must weigh the dangers of unfairness, confusion, and undue expenditure of time in the trial of collateral issues against the factors favoring admissibility.\u2019 McKinnon v. Skil Corp., 638 F.2d 270, 277 (1st Cir. 1981).\u201d\nSee also Ficken v. Alton & Southern Ry. Co., 291 Ill. App. 3d 635, 647-48, 685 N.E.2d 1, 10 (1996) (the trial court has discretion to exclude evidence not directly related to the central issue of the case if the confusion of issues resulting from its admission would not be compensated for by its usefulness in the trial). We will not reverse the trial court\u2019s decision regarding the admission of prior occurrence evidence absent an abuse of discretion. Mikus, 312 Ill. App. 3d at 22, 726 N.E.2d at 105.\nIn this case, the trial court allowed several witnesses, including Robyn Mitchell, Russell Armstrong, Patricia Crabtree, Tanya Spencer, and Beverly Stephens, to testify that they had been driving 1996 or 1997 J-cars when the driver\u2019s-side air bag inadvertently deployed, knocking their hands off the steering wheel and creating noise and smoke. However, the court excluded testimony concerning postdeployment events, including some witnesses\u2019 testimony that air bags struck them or caused them to lose control of their cars. In that regard, plaintiffs presented the following testimony in offers of proof. Mitchell\u2019s air bag hit her in the face and obscured her vision. Mitchell did not state that the deployment caused her to lose control of her car. Armstrong\u2019s air bag hit him in the face and blocked his vision. He did not remember whether the air bag knocked his hands off the steering wheel; however, it \u201cdidn\u2019t matter because [he] was going so slowly.\u201d Crabtree\u2019s air bag hit and injured her, but it did not cause her to lose control of her car. Spencer\u2019s air bag did not hit her, nor did she lose control of her car. Stephen\u2019s air bag hit and injured her, causing her to lose control of her car. Erin Dali\u2019s air bag in her 1998 Cavalier struck her in her face. Dali did not state that the deployment caused her to lose control of her car. Finally, Leanna Snyder\u2019s air bag hit her in the arm, and she blacked out and \u201cended up in a culvert.\u201d However, she did not recall if the air bag hit her in the head. Unlike the other similar-occurrence witnesses, Snyder\u2019s SDM data showed a high delta-v, inconsistent with an inadvertent deployment.\nAt trial, plaintiffs claimed that Danielle\u2019s air bag hit her in the face, knocked her out, and caused her to lose control of the Cavalier. In contrast, none of the similar-occurrence witnesses testified that the air-bag deployment knocked them out. In addition, neither Mitchell, Armstrong, nor Dali testified that the air-bag deployment caused him or her to lose control of his or her car, and Crabtree and Spencer actually testified that the deployment did not cause them to lose control of their cars. Further, the record showed that Dali was driving a 1998 Cavalier, a model year that was not under recall.\nIn limiting the testimony of the similar-occurrence witnesses, the trial court stated, in pertinent part, as follows:\n\u201c[W]e are getting into another area that could be a trial within a trial as to whether or not it did, should have, would have, made contact with [the similar-occurrence witnesses\u2019] heads within the conte[x]t of their occurrences. And so I can\u2019t see where that is going to help anyone, whether it be the plaintiffis] or the defendants]. The jury needs to confine itself to what occurred in this instance and not draw conclusions, either favorably or unfavorably, as to what took place in this case based upon other occurrences.\nSo that general area, meaning as far as the air bag making contact with an individual, who was driving a similar car, with their head area, I don\u2019t think helps or assists the trier of fact in this case in making the determination on the issues that pertain to this case.\u201d\nReviewing the trial court\u2019s decision under the appropriate standard of review, we conclude that the court did not abuse its discretion by excluding the similar-occurrence witnesses\u2019 testimony that their inadvertently deployed air bags struck them and, in some cases, caused them to lose control of their cars.\nMoreover, even if the exclusion of that testimony was error, we conclude that it was harmless. As earlier discussed, a reviewing court will grant reversal based on evidentiary rulings only when the error was substantially prejudicial and affected the outcome of the trial. Conversely, where it appears that an error did not affect the outcome of the trial, or where the reviewing court can see from the entire record that the error did not result in substantial prejudice, the judgment will not be disturbed. Simmons, 198 Ill. 2d at 566-67, 763 N.E.2d at 736. The burden is on the party seeking reversal to establish prejudice. Hallbeck, 269 Ill. App. 3d at 895, 647 N.E.2d at 625. The excluded evidence related to whether the inadvertent deployment of Danielle\u2019s air bag caused her to lose control of the Cavalier and collide with Reed\u2019s, step van. However, the jury explicitly found that Danielle\u2019s air bag did not inadvertently deploy and did not reach the issue of causation. Accordingly, because the error related to the causation issue, which was never reached by the jury, that error was harmless. See Cairns, 170 Ill. App. 3d at 512, 524 N.E.2d at 944 (concluding that the trial court\u2019s erroneous evidentiary ruling was harmless where the error related to an issue the jury never reached).\nD. The Trial Court\u2019s Decision To Allow Evidence Regarding SDM Data Downloaded from the Similar-Occurrence Witnesses\u2019 Vehicles\nPlaintiffs next argue that the trial court erred by denying their motion in limine to exclude evidence regarding the SDM data downloaded from the similar-occurrence witnesses\u2019 J-cars. Specifically, they contend that (1) defendants offered the evidence regarding the similar-occurrence witnesses\u2019 delta-velocities to \u201cnegate causation\u201d despite the fact that such causation evidence \u201cwas not permitted within the [p] lain tiffs\u2019 case,\u201d (2) defendants failed to \u201cestablish foundation\u201d for the SDM data of the similar-occurrence witnesses, and (3) evidence regarding the similar-occurrence witnesses\u2019 delta-velocities \u201cwas not probative.\u201d We disagree.\n1. Purpose of the SDM Data\nPlaintiffs first contend that defendants offered the evidence regarding the similar-occurrence witnesses\u2019 delta-velocities to \u201cnegate causation\u201d despite the fact that such causation evidence \u201cwas not permitted within the [plaintiffs\u2019 case.\u201d We disagree.\nContrary to plaintiffs\u2019 contention, the record shows that the complained-of delta-v evidence had nothing to do with the causation evidence that \u201cwas not permitted within the [plaintiffs\u2019 case\u201d \u2014 that is, whether the inadvertently deployed air bags struck the similar-occurrence witnesses or caused them to lose control of their cars. Instead, the delta-v evidence was offered to support defendants\u2019 theory that Danielle\u2019s air bag did not inadvertently deploy. The trial court allowed plaintiffs to present evidence showing that the similar-occurrence witnesses\u2019 air bags inadvertently deployed, and defendants were allowed to present evidence showing that the delta-v\u2019s of those inadvertent deployments (which ranged from zero to three miles per hour) were different from Danielle\u2019s delta-v of just over 16 miles per hour. As plaintiffs ultimately concede in their brief, \u201c[t]he jury may have easily inferred that [Danielle\u2019s] air[ ]bag did not inadvertently deploy because [Danielle\u2019s] delta-v was not in the range of 0 to 3 miles per hour.\u201d The court did not abuse its discretion by allowing defendants to present evidence central to their defense and directly responsive to plaintiffs\u2019 evidence. See Kelley v. American Motors Corp., 130 Ill. App. 3d 662, 672, 474 N.E.2d 814, 821 (1985) (holding that the trial court erred by allowing the plaintiff to present accident reconstruction evidence but precluding the defendant from presenting such evidence).\n2. Foundation for the SDM Data\nPlaintiffs next contend that defendants failed to \u201cestablish foundation\u201d for the SDM data of the similar-occurrence witnesses. We disagree.\nThe exhibits, graphs, and PowerPoint demonstrations about which plaintiffs complain set forth data that were downloaded from the SDMs in the similar-occurrence witnesses\u2019 J-cars. \u201cRecords directly generated by the computer itself are generally admissible as representing the tangible result of the computer\u2019s internal operations.\u201d In re Marriage of DeLarco, 313 Ill. App. 3d 107, 114, 728 N.E.2d 1278, 1286 (2000). All that need be shown is that the recording device was accurate and operating properly when the evidence was generated. People v. Houston, 288 Ill. App. 3d 90, 98, 679 N.E.2d 1244, 1249 (1997). The accuracy of the SDM\u2019s recording function was established during the Frye hearing in this case. Accordingly, we conclude that defendants satisfied the foundational requirements for the SDM-generated data from the similar-occurrence witnesses\u2019 J-cars.\nWe also agree with defendants that the exhibits were admissible under the business records exception to the hearsay rule. Supreme Court Rule 236(a) requires only that the party tendering the record satisfy the foundation requirement by demonstrating that the record was made in the regular course of a business at or near the time of the transaction. 145 Ill. 2d R. 236(a); Progress Printing Corp. v. Jane Byrne Political Committee, 235 Ill. App. 3d 292, 305, 601 N.E.2d 1055, 1064 (1992). \u201c \u2018[A]ll other circumstances of the making of the writing or record, including lack of personal knowledge by the entrant or maker, may be shown to affect its weight, but shall not affect its admissibility.\u2019 \u201d Lecroy v. Miller, 272 Ill. App. 3d 925, 935-36, 651 N.E.2d 617, 624 (1995), quoting 145 Ill. 2d R. 236(a); see also Raithel v. Dust-cutter, Inc., 261 Ill. App. 3d 904, 909, 634 N.E.2d 1163, 1167 (1994) (Cook, J., specially concurring) (A business can prove up records of another business which it has in its possession if it verified those records).\nIn this case, Nunan testified that (1) he was familiar with General Motors\u2019 records and procedures regarding the reports generated during the 1241 investigation, and (2) the SDM data was retrieved and kept in the normal course of the investigation. Up until 2000, Delphi (for whom Nunan worked) was affiliated with General Motors, and Nunan had worked on the SDM for years alongside General Motors. Nunan also stated that \u201c[w]hen [an inadvertent-deployment] complaint came in we investigated it, and part of that would be obtaining the SDM data to try to come to a conclusion about what occurred.\u201d In addition, McConnell testified that after an inadvertent-deployment complaint was called in, the information was recorded \u201crather promptly\u201d in the regular course of business. A file on the complaint would be sent to a customer assistance manager \u201cwithin the same day or no later than the next business day.\u201d The manager would then send a district service manager to investigate and \u201cretrieve that [SDM] information.\u201d Under these circumstances, we conclude that defendants satisfied the threshold requirement for admission of the SDM data under the business records exception.\n3. Probative Value of the SDM Data\nLast, plaintiffs contend that the evidence regarding the similar-occurrence witnesses\u2019 delta-velocities was not probative because \u201cthe vertical velocity could affect the longitudinal velocity, and thereby affect the delta-v of these 1996 and 1997 Chevrolet Cavaliers.\u201d\nPlaintiffs have forfeited this argument on appeal by failing to raise that specific objection in the trial court. See McIntyre v. Harris, 304 Ill. App. 3d 304, 309, 709 N.E.2d 982, 985 (1999) (when an objection is made in the trial court, the specific grounds must be stated, and other grounds not stated are forfeited on appeal).\nE. The Trial Court\u2019s Denial of Plaintiffs\u2019 Motion To Bar\nDefendants\u2019 Opinion Witnesses for Alleged Discovery Violations\nPlaintiffs next argue that the trial court erred by denying their motion in limine, seeking to bar defendants\u2019 opinion witnesses for alleged discovery violations. We disagree.\n1. Standard of Review\nSupreme Court Rule 219(c) provides that where a party unreasonably refuses to comply with discovery rules or orders, the trial court may enter \u201csuch orders as are just\u201d to remedy the situation. 166 Ill. 2d R. 219(c). The court\u2019s purpose in imposing sanctions is not to punish a party. In fashioning a sanction, the court must weigh the competing interests of the offending party\u2019s right to maintain a lawsuit against the need to accomplish the objectives of discovery and promote the unimpeded flow of litigation. Sander v. Dow Chemical Co., 166 Ill. 2d 48, 68, 651 N.E.2d 1071, 1081 (1995). In considering whether a particular sanction is appropriate, a court must consider the conduct of the offending party and the effect of that conduct upon the opposing party. Smith v. P.A.C.E., 323 Ill. App. 3d 1067, 1075, 753 N.E.2d 353, 361 (2001). \u201cDismissal or entry of a default judgment is a severe sanction and should be invoked only in cases where the party\u2019s actions exhibit a deliberate, contumacious, or unwarranted disregard of the court\u2019s authority and after all the other court\u2019s enforcement powers have failed to advance the litigation.\u201d In re Marriage of Booher, 313 Ill. App. 3d 356, 359, 728 N.E.2d 1230, 1232-33 (2000). The decision to impose a particular sanction \u2014 if any \u2014 lies within the trial court\u2019s discretion, and only a clear abuse of discretion justifies reversal. Blakey v. Gilbane Building Corp., 303 Ill. App. 3d 872, 877, 708 N.E.2d 1187, 1191 (1999).\n2. Defendants\u2019 Alleged Failure To Timely File Interrogatory Answers\nPlaintiffs first contend that the trial court erred by denying their motion in limine, seeking to bar defendants\u2019 19 expert and lay opinion witnesses based on defendants\u2019 failure to timely file answers to interrogatories. Specifically, they contend that \u201c [defendants introduced numerous exhibits and testimony by its witnesses, including Doug Nu-nan\u2019s testimony, that were never disclosed by way of [Rule] 213(g) interrogatory [(177 Ill. 2d R. 213(g))] to the surprise and prejudice to [p]laintiffs.\u201d\nInitially, we note that plaintiffs failed to make contemporaneous objections on this ground during the testimony of 16 of defendants\u2019 19 opinion witnesses. (The record shows that plaintiffs raised contemporaneous Rule 213(g) objections only during the testimony of Sonye (which the trial court sustained), Law, and McKenna.) Although plaintiffs objected during Nunan\u2019s testimony regarding the delta-velocities of the similar-occurrence witnesses\u2019 J-cars (which is the only testimony about which plaintiffs specifically complain on appeal), those objections were on the grounds of (1) foundation and (2) relevance, not Rule 213(g). Plaintiffs thus have forfeited this issue on appeal, except as it relates to Law and McKenna (which we address in section II. H. 2 below). See Jones v. Chicago Osteopathic Hospital, 316 Ill. App. 3d 1121, 1132, 738 N.E.2d 542, 552 (2000) (\u201cBecause an in limine order always remains subject to reconsideration by the court during trial, an in limine motion, whether granted or denied, does not preserve issues for review\u201d); Zook v. Norfolk & Western Ry. Co., 268 Ill. App. 3d 157, 162, 642 N.E.2d 1348, 1352 (1994) (\u201cWhen a motion in limine is denied, the unsuccessful movant must specifically object to the evidence when it is offered by the other party at trial\u201d); see also Ficken, 291 Ill. App. 3d at 645, 685 N.E.2d at 8 (a party must state specific grounds for any objections, and other grounds not stated are waived on review).\nMoreover, we agree with the trial court\u2019s ruling on the merits. The record shows that on April 25, 2000, the court entered a case management conference order, providing that (1) \u201c[a]ll written discovery [was to] be completed by June 1, 2000,\u201d (2) defendants were to disclose opinion witnesses in accordance with the requirements of Supreme Court Rule 213(g) by August 6, 2000, and (3) plaintiffs were to complete depositions of defendants\u2019 opinion witnesses by September 6, 2000. On July 24, 2000, plaintiffs served defendants with purported Rule 213(g) interrogatories, which sought information beyond that required by Rule 213(g). (For example, the interrogatories sought each witness\u2019s prior employment history and a description of other litigation in which each had consulted.) On August 2, 2000, defendants objected that the interrogatories were overbroad and untimely. Nonetheless, defendants offered to disclose in \u201cfull compliance with Rule 213(g)\u201d and the court\u2019s April 2000 order by plaintiffs\u2019 August 6, 2000, deadline. The record shows that defendants submitted their interrogatory answers on August 7, 2000. Defendants listed 19 potential opinion witnesses, set out each witness\u2019s qualifications, the subject matter about which each would testify, the witnesses\u2019 opinions and bases therefor, and attached the witnesses\u2019 reports.\nOn September 25, 2000, plaintiffs moved to bar all 19 of defendants\u2019 opinion witnesses for defendants\u2019 failure to answer plaintiffs\u2019 interrogatories. Following an October 2000 hearing, at which plaintiffs admitted that their interrogatories exceeded the scope of Rule 213(g), the trial court denied plaintiffs\u2019 motion, stating, in pertinent part, as follows:\n\u201cThe [c]ourt notes that [plaintiffs\u2019] [Rule] 213(g) interrogatories were served upon the defendants past the discovery cutoff date, that the discovery request went beyond that provided by Supreme Court Rule 213 and that [c]ounsel for defense did not ignore those interrogatories but did provide substantial compliance with the rule within their answers.\nIn addition, most of the witnesses have either been disclosed along with their opinions and deposed as well and/or now, based upon the [c]ourt\u2019s earlier ruling today, will not be allowed to testify.\u201d\nUnder these circumstances, we conclude that the trial court did not clearly abuse its discretion by denying plaintiffs\u2019 motion to bar defendants\u2019 19 opinion witnesses. Indeed, plaintiffs do not contest on appeal the court\u2019s finding that plaintiffs\u2019 interrogatories \u201cwent beyond\u201d Rule 213(g) (177 Ill. 2d R. 213(g)).\nAlthough not set out as a separate argument, plaintiffs also contend that the trial court erred by denying their motion to bar defendants\u2019 19 expert and lay opinion witnesses because \u201c[i]t is undisputed that defendants failed to timely respond\u201d to plaintiffs\u2019 November 18, 1998, document request. Plaintiffs have forfeited this issue on appeal by failing to raise it in the trial court. We will not reverse the trial court\u2019s decision based on an argument the trial court never heard. Seef v. Ingalls Memorial Hospital, 311 Ill. App. 3d 7, 23, 724 N.E.2d 115, 127 (1999).\n3. Defendants\u2019 Alleged Failure To Allow Plaintiffs To Redepose Certain Witnesses\nPlaintiffs next contend that the trial court erred by denying their motions to bar Everest, Schultz, Sonye, Mercer, B.J. Turner, and Gary Bahling from testifying on the ground that defendants refused to allow plaintiffs to redepose those witnesses following the filing of defendants\u2019 Rule 213(g) answers. Specifically, they contend that \u201cas [defendants refused to allow [p]laintiffs to redepose these witnesses, [p]laintiffs were precluded from determining the opinions of these witnesses, which may have aided [p] lain tiffs in the trial.\u201d\nPlaintiffs have forfeited this issue on appeal by calling as witnesses the only four of those six witnesses who testified at trial. See Chubb/Home Insurance Cos. v. Outboard Marine Corp., 238 Ill. App. 3d 558, 568, 606 N.E.2d 423, 430 (1992) (\u201cA party cannot complain of evidence which he himself introduced or brought out\u201d). Further, we note that at the October 2000 hearing on plaintiffs\u2019 motions, defendants twice offered to allow plaintiffs to redepose those witnesses, but plaintiffs failed to exercise that opportunity.\nMoreover, even accepting plaintiffs\u2019 contention that the trial court erred by denying plaintiffs\u2019 motions to bar those six witnesses from testifying, plaintiffs have failed to meet their burden of showing prejudice that affected the outcome of the trial. See Hallbeck, 269 Ill. App. 3d at 895, 647 N.E.2d at 625 (the burden is on the party seeking reversal to establish prejudice). Plaintiffs\u2019 bald assertion that the trial court\u2019s \u201crefusal to bar these opinion witnesses constituted reversible error and severe prejudice to the [pjlain tiffs herein, as a matter of law\u201d does not show substantial prejudice affecting the outcome of the trial.\n4. Defendants\u2019 Disclosure of Certain Documents Fewer Than 60 Days Before Trial\nPlaintiffs also contend that the trial court erred by denying their motion to bar defendants\u2019 opinion witnesses based on defendants\u2019 disclosure of approximately 13,000 pages of documents fewer than 60 days before trial. Plaintiffs acknowledge that the court sanctioned defendants by ordering that (1) plaintiffs themselves could use any untimely produced document; and (2) only if plaintiffs used such a document could defendants use the same document in their defense. However, they contend that the court\u2019s order \u201cwas insufficient and inadequate to cure the prejudice and surprise of the late disclosure.\u201d We disagree.\nIn August 1999, in response to plaintiffs\u2019 request for production, defendants produced a copy of its \u201ccrash and sled test\u201d database for 1996 and 1997 J-cars and invited plaintiffs to select those tests for which they wanted reports, video, or test set-up sheets. In April 2000, defendants reminded plaintiffs of the list of crash and sled tests; however, plaintiffs apparently never selected any of the crash tests for production. On May 31, 2000, plaintiffs served a supplemental production request, and in mid-September 2000, defendants produced a 100-page software definition document for the SDM and approximately 3,600 pages of crash test materials.\nLater in September 2000, plaintiffs filed a motion for discovery sanctions, pursuant to Supreme Court Rule 219 (166 Ill. 2d R. 219), seeking either (1) j\u00fadgment on the issue of liability or (2) to \u201cbar any and all evidence, expert and nonexpert\u201d relating to the SDM. At the September 2000 hearing on plaintiffs\u2019 motion for sanctions, defendants informed the trial court that more crash test documents would be forthcoming. The court told defendants to produce those documents and informed the parties that those documents would also be subject to the court\u2019s order on plaintiffs\u2019 motion. In October 2000, the court entered a written order, finding that the documents produced in September 2000 were not timely disclosed and ordering that those documents \u201cshall not be used or relied on by [d]efendant[s] at trial\u201d but that plaintiffs \u201cmay use any of the aforesaid documents,\u201d and if they did, defendants could use \u201cany of the same\u201d in their defense or rebuttal. The court also found that in August 1999, defendants had timely produced a substantially identical software definition document for the SDM (product definition document). (Plaintiffs acknowledged that the software definition document produced in September 2000 was \u201cduplicitous in a lot of respects\u201d of the product definition document.)\nOn October 9, 2000, defendants produced the additional crash test documents (totaling approximately 10,000 pages). Later that month, plaintiffs filed a second motion for sanctions, alleging that defendants had untimely disclosed the crash test documents and the software definition document and once again seeking either (1) judgment on the issue of liability or (2) to \u201cbar any and all evidence, expert and nonexpert\u201d relating to the SDM.\nFollowing a November 2000 hearing, the trial court reaffirmed its prior ruling and denied plaintiffs\u2019 second motion for sanctions. In so doing, the court stated, in pertinent part, as follows:\n\u201cWith regard to plaintiffis\u2019] second motion for sanctions, the court has previously held the documents submitted by the defendants on September 14 of this year were untimely, and that although plaintiffs would be permitted to use any of those documents at trial, the defendants could not unless the plaintiffs used them first.\n\u00ed\u00a1\u00ed j!:\nAny crash test that was produced after September 14 of this year by defendants to the plaintiff may not be used unless the plaintiffis] use[ ] them first. The court did in fact direct the defendants to produce those reports on September 22 subject to those conditions. So there is nothing new, in essence, which I have dealt with thus far based upon the court\u2019s prior order.\nWith regard to the sensing algorithm, there is material in both documents *** the software definition document and the product definition document that pertains to this issue.\n$ $ ^\nFurther, there was testimony *** [that] the product definition document and the calibration specifications *** were provided prior to the September materials being provided to the plaintiffis], and that that information would have been sufficient for plaintiffis\u2019] expert or experts in order to render an opinion contrary to or in opposition to what is anticipated that defendants\u2019 experts will be testifying to in this matter.\u201d\nUnder the circumstances of this case, we conclude that the trial court did not clearly abuse its discretion by denying plaintiffs\u2019 motion to bar defendants\u2019 opinion witnesses, and instead, ordering that documents produced on or after September 14, 2000, could not be used by defendants unless plaintiffs first used them. See Martinez v. Pfizer Laboratories Division, 216 Ill. App. 3d 360, 373, 576 N.E.2d 311, 320 (1991) (\u201c[A] \u2018just order\u2019 under Rule 219(c) is one which, to the degree possible, ensures both the accomplishment of discovery and a trial on the merits\u201d); see also Booher, 313 Ill. App. 3d at 361, 728 N.E.2d at 1234 (\u201cA reasonable sanction for failure to comply with an order for discovery providing information *** when much of the information was already disclosed in previous discovery, would be one barring [the offending party] from contradicting or going beyond the discovery materials provided on those matters\u201d (emphasis in original)).\nE The Trial Court\u2019s Decision Permitting the Jury To View Danielle\u2019s Damaged Cavalier\nPlaintiffs next argue that the trial court erred by permitting the jury to view Danielle\u2019s damaged Cavalier during defendants\u2019 case in chief. Specifically, they contend that the jury\u2019s viewing of the Cavalier constituted an abuse of discretion \u201csince both parties had hundreds of photographs accurately and truly portraying the damage to [Danielle\u2019s] vehicle.\u201d We disagree.\nDemonstrative evidence has no probative value in itself but serves as a visual aid to the jury in comprehending witnesses\u2019 verbal testimony. Schuler v. Mid-Central Cardiology, 313 Ill. App. 3d 326, 337, 729 N.E.2d 536, 545 (2000); see Lundquist v. Nickels, 238 Ill. App. 3d 410, 427, 605 N.E.2d 1373, 1385 (1992) (the jury\u2019s viewing of property involved in the litigation \u201cdoes not constitute evidence, but is merely a device to facilitate the jury\u2019s understanding and application of the evidence to the issues presented at trial\u201d). Courts look favorably upon the use of demonstrative evidence, because it helps the jury understand the issues raised at trial. People v. Burrows, 148 Ill. 2d 196, 252, 592 N.E.2d 997, 1022 (1992); Schuler, 313 Ill. App. 3d at 337, 729 N.E.2d at 545. The considerations in determining whether demonstrative evidence should be allowed are relevancy and fairness, and the decision whether to allow a party to present demonstrative evidence lies within the trial court\u2019s discretion. Schuler, 313 Ill. App. 3d at 337, 729 N.E.2d at 545. Thus, we will not reverse a trial court\u2019s decision regarding demonstrative evidence absent a clear abuse of discretion. Herman v. Will Township, 284 Ill. App. 3d 53, 62, 671 N.E.2d 1141, 1147 (1996).\nIn this case, the damage to Danielle\u2019s Cavalier was clearly relevant. Plaintiffs\u2019 own accident-reconstruction expert, Van Daele, acknowledged that to determine what happened in the accident, \u201cthe best thing would be to actually look at the vehicle as opposed to a two-dimensional photograph.\u201d\nNor was the jury\u2019s viewing of the Cavalier unfair or confusing. Prior to the jury\u2019s viewing, the trial court admonished the jury that the viewing was a \u201cdemonstrative aid *** to assist [the jurors] in understanding the testimony that ha[d] been elicited by the witnesses and the exhibits *** which ha[d] been received into evidence.\u201d After the viewing, the court also explained to the jury that videotape had been taken of the Cavalier to ensure that a complete record of the trial proceedings was made. The jury\u2019s viewing of the Cavalier was simply an aid used to explain the collision between Reed\u2019s step van and Danielle\u2019s Cavalier, a topic the witnesses would testify about with or without the viewing. Indeed, during cross-examination of Thebert, defendants\u2019 accident-reconstruction expert, plaintiffs\u2019 counsel stated that plaintiffs wanted the jury \u201cto see this damage to the vehicle.\u201d Under these circumstances, we conclude that the trial court did not abuse its discretion by allowing the jury to view Danielle\u2019s Cavalier.\nAlthough not set out as a separate argument, plaintiffs also argue that they were \u201cseverely prejudiced\u201d when Thebert \u201cexpressly and impliedly testified that the viewing of [Danielle\u2019s] vehicle would establish certain facts, which supported his testimony.\u201d As defendants correctly point out, plaintiffs did not object to Thebert\u2019s testimony (in which he suggested that the jury focus on particular parts of the Cavalier, including the left rear suspension area, the inside of the car, and the paint transfer). Thus, plaintiffs have forfeited this issue on appeal. See Kotvan, 321 Ill. App. 3d at 750, 747 N.E.2d at 1059 (\u201c \u2018Preservation of a question for review requires an appropriate objection in the court below [citation], and failure to object constitutes waiver.\u2019 Williamsburg, 200 Ill. App. 3d at 479, 558 N.E.2d at 211\u201d).\nG. The Trial Court\u2019s Decision Allowing Seckler To Testify\nRegarding the Dangerousness of the Curve Where Danielle\u2019s Collision Occurred\nPlaintiffs also argue that the trial court erred by denying plaintiffs\u2019 motion in limine seeking to preclude Seckler from testifying that based on her personal experience, if a person drives around the curve at more than 35 miles per hour, that person could lose control and cross the centerline. Specifically, they contend that Seckler\u2019s testimony was \u201cirrelevant and immaterial\u201d and prejudicial to plaintiffs\u2019 case. We disagree.\nGenerally, relevant evidence is admissible. Hiscott v. Peters, 324 Ill. App. 3d 114, 124, 754 N.E.2d 839, 849 (2001). \u201cEvidence is relevant if it tends to either prove a fact in controversy or render a matter in issue more or less probable, and each party may present evidence relevant to his theory of the case or inconsistent with an opponent\u2019s theory.\u201d Galowich v. Beech Aircraft Corp., 209 Ill. App. 3d 128, 135, 568 N.E.2d 46, 50 (1991). The determination as to what is relevant evidence is a matter within the trial court\u2019s sound discretion, and we will not disturb the trial court\u2019s determination absent an abuse of that discretion. Schuler, 313 Ill. App. 3d at 336, 729 N.E.2d at 544.\nIn this case, the trial court carefully weighed the parties\u2019 arguments and determined that the disputed evidence would be admitted. Reviewing the record, we cannot say that the court\u2019s decision in this regard was \u201carbitrary, fanciful[,] or unreasonable.\u201d Illgen, 145 Ill. 2d at 364, 583 N.E.2d at 519 (discussing the abuse of discretion standard).\nIn so concluding, we note that plaintiffs\u2019 contention that Seckler\u2019s testimony was \u201cirrelevant\u201d and \u201cimmaterial\u201d is belied by plaintiffs\u2019 concession in their brief that the testimony \u201cgave credence to\u201d and \u201cconveyed to the jury\u201d defendants\u2019 theory of. the case \u2014 that the collision was not caused by the inadvertent deployment of Danielle\u2019s air bag, but by Danielle\u2019s speeding. See Sobczak, 302 Ill. App. 3d at 929, 706 N.E.2d at 1000 (\u201cIt is well settled that evidence is relevant under Illinois law when it has any tendency to make the existence of any fact that is of consequence to the determination of the action more or less probable than it would be without the evidence\u201d).\nMoreover, even accepting plaintiffs\u2019 contention that the trial court erred by allowing Seckler\u2019s testimony, our review of the record shows that the error was harmless. Seckler\u2019s testimony regarding the danger of losing control on the Nofsinger Road curve was largely cumulative of several of plaintiffs\u2019 own witnesses. Both William Gray and Van Daele testified that the curve was dangerous, and Van Daele acknowledged that when he inspected the scene following the collision, he saw cars go into the opposite lane of traffic as they were attempting to negotiate the curve. Schneider testified that at speeds of 45 to 50 miles per hour, the bumps on Nofsinger Road present a problem. In addition, Ricki Gray testified that when driving her car around the curve near the \u201crippled\u201d section of the road, it gave her the \u201cfeeling that [she] want[ed] to lose control.\u201d See People v. Sparks, 314 Ill. App. 3d 268, 273, 731 N.E.2d 987, 991 (2000) (concluding that error in admitting certain evidence was harmless when the jury was \u201cpresented with [the same] version of events independently of any prejudicial effect that the error may have had\u201d).\nH. The Trial Court\u2019s Decision To Allow Evidence Regarding Danielle\u2019s Seat Belt Use and the Condition of Her Seat Belt Following the Collision\nPlaintiffs next argue that the trial court erred by granting defendants\u2019 motion in limine to allow McKenna to testify that (1) Danielle was wearing her seat belt during the collision; and (2) his postcollision inspection of her seat belt showed physical signs of Danielle\u2019s forward movement during the collision. Specifically, they contend that (1) section 12 \u2014 603.1(c) of the Illinois Vehicle Code (Vehicle Code) prohibits evidence that a person used a seat belt (625 ILCS 5/12 \u2014 603.1(c) (West 1996)) and (2) defendants did not adequately disclose McKenna\u2019s opinions, pursuant to Supreme Court Rule 213(g) (177 Ill. 2d R. 213(g)). We disagree.\nInitially, we note that plaintiffs have forfeited this issue on appeal by calling several witnesses who testified that Danielle was wearing her seat belt during the collision. See Chubb [Home Insurance Cos., 238 Ill. App. 3d at 568, 606 N.E.2d at 430 (\u201cA party cannot complain of evidence which he himself introduced or brought out\u201d).\nEven assuming plaintiffs had not forfeited this issue on appeal, we conclude that the trial court did not abuse its discretion by allowing McKenna\u2019s seat-belt testimony.\n1. Section 12 \u2014 603.1(c) of the Vehicle Code\nPlaintiffs first contend that the trial court should have excluded McKenna\u2019s testimony that Danielle was wearing her seat belt during the collision, pursuant to section 12 \u2014 603.1(c) of the Vehicle Code (625 ILCS 5/12 \u2014 603.1(c) (West 1996)). We disagree.\nSection 12 \u2014 603.1(c) of the Vehicle Code provides, in pertinent part, that \u201c[fjailure to wear a seat safety belt in violation of this [section shall not be considered evidence of negligence.\u201d 625 ILCS 5/12\u2014 603.1(c) (West 1996). That section does not preclude all seat-belt evidence, but only evidence of nonuse in determining whether the person was negligent in failing to utilize the vehicle\u2019s seat-belt system.\nIn rejecting the argument that McKenna\u2019s testimony was prohibited under section 12 \u2014 603.1(c), which was set forth in plaintiffs\u2019 response to defendants\u2019 motion in limine, the trial court stated as follows:\n\u201c[Regarding t]he motion in limine to admit evidence concerning the seat belt, the court finds that the relevant statutory provision, 625 ILCS 5/12 \u2014 603.1(c) [(West 1996)], is inapplicable. The statute addresses the failure to wear seat belts. The purpose of the testimony that is sought to be introduced in this case has nothing to do with [Danielle\u2019s] negligence or [with] minimizing] the damages of the plaintifffs].\nThe evidence of the seat[-]belt use is relevant for the limited purpose of establishing whether or not [Danielle] was involved in a frontal [or] side[-]impact collision.\nThe defendants[ ] ought and will be allowed to contest the plaintiffs\u2019 claim of inadvertent deployment.\u201d\nWe agree with the trial court. We thus conclude that the court did not abuse its discretion by allowing McKenna to testify that Danielle was wearing her seat belt during the collision. See City of Quincy v. Diamond Construction Co., 327 Ill. App. 3d 338, 343, 762 N.E.2d 710, 714 (2002) (a reviewing court will not reverse a trial court\u2019s decision to grant or deny a motion in limine absent a clear abuse of discretion).\n2. Supreme Court Rule 213(g)\nPlaintiffs also contend that the trial court abused its discretion by allowing McKenna\u2019s seat-belt testimony because defendants did not adequately disclose his opinions, pursuant to Supreme Court Rule 213(g) (177 Ill. 2d R. 213(g)). Specifically, they assert that the court erred by determining that McKenna\u2019s testimony (that the marks on Danielle\u2019s seat belt showed physical signs of her forward movement during the collision) was not encompassed by McKenna\u2019s original opinion set forth in his interrogatory answers that \u201csome plastic and other load cariying parts [of the seat belt] were clearly marked from occupant forces.\u201d We disagree.\nSupreme Court Rule 213(g) requires that parties disclose the subject matter, conclusions, opinions, qualifications, and all reports of a witness who will offer any opinion testimony. Sinclair v. Berlin, 325 Ill. App. 3d 458, 469, 758 N.E.2d 442, 451 (2001). At trial, a witness may elaborate on a properly disclosed opinion (Becht v. Palac, 317 Ill. App. 3d 1026, 1037, 740 N.E.2d 1131, 1140 (2000)), and \u201c[t]he fact that trial testimony is more precise than the opinion as originally disclosed does not necessarily result in a violation\u201d (Prairie v. Snow Valley Health Resources, Inc., 324 Ill. App. 3d 568, 576, 755 N.E.2d 1021, 1029 (2001)). However, the witness\u2019s testimony must be encompassed by the original opinion. Becht, 317 Ill. App. 3d at 1037, 740 N.E.2d at 1140. A trial court\u2019s decision regarding whether an opinion has been adequately disclosed such that it may be admitted into evidence is a matter committed to the trial court\u2019s sound discretion. Prairie, 324 Ill. App. 3d at 576, 755 N.E.2d at 1029; Sinclair, 325 Ill. App. 3d at 469, 758 N.E.2d at 451. Thus, we will not reverse the trial court\u2019s decision on this matter absent an abuse of discretion. Sinclair, 325 Ill. App. 3d at 469, 758 N.E.2d at 451.\nIn rejecting plaintiffs\u2019 argument that McKenna\u2019s testimony was not encompassed by his original opinion, the trial court found as follows: \u201cAll those opinions have been disclosed, [McKenna] has been examined. There is no new opinion which he is offering which would constitute any surprise or unfair prejudice to the plaintiffs.\u201d Reviewing the trial court\u2019s decision under the appropriate standard of review, we conclude that the court did not abuse its discretion by determining that McKenna\u2019s testimony was an elaboration on his original opinion.\nI. The Trial Court\u2019s Decision To Submit a Special Interrogatory to the Jury\nPlaintiffs next argue that the trial court erred by submitting the following special interrogatory to the jury: \u201cDid the driver\u2019s side air bag inadvertently deploy on November 6, 1996?\u201d Specifically, they contend that (1) the special interrogatory was \u201cdefective as it obviously could not control the general verdict\u201d; (2) the trial court \u201cadvocate[d]\u201d for defendants by \u201cinforming counsel for defendants that if certain language was set forth in the interrogatory, the court would be inclined to accept it\u201d; and (3) the jury was misled and confused by the interrogatory. We disagree.\n1. Form of the Special Interrogatory\nPlaintiffs first contend that the special interrogatory was \u201cobviously defective.\u201d\nInitially, we note that plaintiffs have forfeited this issue on appeal by withdrawing their objection to the form of the special interrogatory. See Green v. Bernstein, 238 Ill. App. 3d 656, 658, 606 N.E.2d 500, 502 (1992) (\u201cIt is well settled that a failure to specifically object to a special interrogatory will waive any objection in the giving of that special interrogatory\u201d).\nEven assuming that plaintiffs had not forfeited this issue, we conclude that the special interrogatory was in proper form. Section 2 \u2014 1108 of the Code provides as follows:\n\u201cThe jury may be required by the court, and must be required on request of any party, to find specially upon any material question or questions of fact submitted to the jury in writing. Special interrogatories shall be tendered, objected to, ruled upon[,] and submitted to the jury as in the case of instructions. Submitting or refusing to submit a question of fact to the jury may be reviewed on appeal, as a ruling on a question of law. When the special finding of fact is inconsistent with the general verdict, the former controls the latter and the court may enter judgment accordingly.\u201d 735 ILCS 5/2 \u2014 1108 (West 1996).\nIn Simmons, 198 Ill. 2d at 563, 763 N.E.2d at 734-35, our supreme court reviewed the law regarding the proper form for special interrogatories and wrote the following:\n\u201c[A] special interrogatory is in proper form if (1) it relates to an ultimate issue of fact upon which the rights of the parties depend, and (2) an answer responsive thereto is inconsistent with some general verdict that might be returned. [Citations.] In addition, it should be a single question, stated in terms that are simple, unambiguous, and understandable; it should not be repetitive, confusing, or misleading. [Citation.] It need not contain all of the elements of negligence and is proper if it focuses on one element that is dispositive of the claim.\u201d\nFurther, in assessing the form of a special interrogatory, the court need not determine whether both a positive and negative answer thereto could control all possible general verdicts. \u201cRather, a special interrogatory is proper if some response to [it] could serve to test some general verdict returned by the jury.\u201d (Emphasis in original.) Eaves v. Hyster Co., 244 Ill. App. 3d 260, 266, 614 N.E.2d 214, 218 (1993).\nBased on these principles, we conclude that defendants\u2019 special interrogatory was in proper form. The interrogatory presented a single and direct question; its terms were simple, understandable, and unambiguous; it was not misleading or repetitive; and a negative response to it would control an inconsistent general verdict by the jury in plaintiffs\u2019 favor.\n2. The Trial Court\u2019s Alleged Assistance in Wording the Special Interrogatory\nPlaintiffs also contend that the trial court \u201cadvocate[d]\u201d for defendants by \u201cinforming counsel for defendants that if certain language was set forth in the interrogatory, the court would be inclined to accept it.\u201d According to plaintiffs, \u201cthe record will reflect that [defendants may have been unable to submit a special interrogatory that the court would have granted.\u201d We disagree.\nContrary to plaintiffs\u2019 contention, the record clearly shows that defendants\u2019 counsel, not the trial court, suggested the special interrogatory that was given. During the jury instruction conference, defendants submitted the special interrogatory, which then provided as follows: \u201cHave the plaintiffs proven by a preponderance of the evidence that the driver\u2019s side air[ ]bag inadvertently deployed on November 6, 1996?\u201d Plaintiffs objected, alleging that the form was improper and the interrogatory included improper language regarding the burden of proof. Defendants\u2019 counsel then stated, in pertinent part, as follows: \u201cWith respect to the form, I do think the interrogatory is proper. If plaintiffs have a problem with using \u2018preponderance of the evidence,\u2019 the interrogatory could be changed to was, you know, [\u2018]did the driver\u2019s side air bag inadvertently deploy on November 6, 1996[?\u2019, which] would take the [\u2018]burden[\u2019] language out if that is unacceptable.\u201d The trial court accepted that suggested language and agreed to submit the interrogatory to the jury. Indeed, plaintiffs\u2019 counsel \u201cacknowledge^] for the record\u201d that defendants\u2019 counsel, not the trial court, suggested the special interrogatory given.\n3. Plaintiffs\u2019 Claim That the Jury Was Confused and Misled by the Special Interrogatory\nLast, plaintiffs contend that the jury was confused and misled by the special interrogatory because the jury did not initially answer the interrogatory when it returned the general verdict. Plaintiffs make this bald assertion without citation either to authority or the record. A point raised but not argued or supported by citation to relevant authority fails to satisfy the requirements of Supreme Court Rule 341(e)(7) (188 Ill. 2d R. 341(e)(7)). Rivera v. Arana, 322 Ill. App. 3d 641, 648, 749 N.E.2d 434, 440 (2001). Accordingly, plaintiffs have forfeited this issue on appeal.\nMoreover, the mere fact that the jury initially returned a general verdict in defendants\u2019 favor without answering the special interrogatory does not manifest confusion on the jury\u2019s part. With the parties\u2019 agreement, the trial court resubmitted the interrogatory to the jury and instructed it to answer and sign it. Once the court clarified the procedure, the jury returned the unanimous negative response consistent with its general verdict. Any \u201cconfusion\u201d on the jury\u2019s part regarded procedure, not the actual question posed. See generally Simmons, 198 Ill. 2d at 566, 763 N.E.2d at 736 (jury\u2019s questions regarding the purpose and necessity of answering a special interrogatory did not display confusion on the jury\u2019s part).\nJ. Plaintiffs\u2019 Claim That the Verdict Was Against the Manifest Weight of the Evidence\nPlaintiffs also argue that the jury verdict was against the manifest weight of the evidence. We disagree.\nA reviewing court will set aside a jury\u2019s verdict only if it was against the manifest weight of the evidence. Rhodes v. Illinois Central Gulf R.R., 172 Ill. 2d 213, 242, 665 N.E.2d 1260, 1274 (1996). Under this standard of review, we will reverse a jury verdict only (1) if it is unreasonable, arbitrary, and not based on evidence, or (2) when the opposite conclusion is clearly apparent to us. O\u2019Donnell v. Holy Family Hospital, 289 Ill. App. 3d 634, 643, 682 N.E.2d 386, 393 (1997). Reviewing courts should scrutinize the evidence but may not sit as a second jury and reweigh the evidence or reevaluate the credibility of the witnesses, especially where conflicting opinion testimony is introduced at trial. O\u2019Donnell, 289 Ill. App. 3d at 643, 682 N.E.2d at 393.\nThis case involved a battle of witnesses \u2014 both lay and expert. Witnesses qualified in their fields stated their opinions and gave their reasons for those opinions. Not surprisingly, plaintiffs\u2019 experts did not agree with the defense experts. It was the jury\u2019s job to listen to the conflicting evidence in this case and use its best judgment to determine where the truth could be found. The jury found in favor of defendants and against plaintiffs, and this court \u201cshould not usurp the function of the jury and substitute its judgment on questions of fact fairly submitted, tried, and determined from the evidence which did not greatly preponderate either way.\u201d Maple v. Gustafson, 151 Ill. 2d 445, 452-53, 603 N.E.2d 508, 512 (1992). We therefore will not disturb the jury\u2019s determination here.\nK. The Trial Court\u2019s Denial of Plaintiffs\u2019 Motion for Punitive Damages\nPlaintiffs next argue that the trial court erred by denying plaintiffs\u2019 motion to amend their complaint to add a punitive damages prayer, pursuant to section 2 \u2014 604.1 of the Code (735 ILCS 5/2 \u2014 604.1 (West 1996))'\nIn light of the jury\u2019s verdict in favor of defendants and against plaintiffs (which we concluded was not against the manifest weight of the evidence), plaintiffs have not proved that they suffered damage. Punitive damages \u201c \u2018are in addition to compensatory damages and cannot be allowed unless actual damage is shown.\u2019 \u201d Hayman v. Autohaus on Edens, Inc., 315 Ill. App. 3d 1075, 1078, 734 N.E.2d 1012, 1015 (2000), quoting In re Application of Busse, 124 Ill. App. 3d 433, 438, 464 N.E.2d 651, 655 (1984); see also Florsheim v. Travelers Indemnity Co. of Illinois, 75 Ill. App. 3d 298, 310, 393 N.E.2d 1223, 1233 (1979) (\u201cthe plaintiff can only be awarded punitive damages where actual damage is shown\u201d). Accordingly, we need not address plaintiffs\u2019 punitive damages argument.\nMoreover, reviewing the record, we conclude that the trial court did not err by denying plaintiffs\u2019 motion to amend their complaint to add a prayer for punitive damages. See Stojkovich v. Monadnock Building, 281 Ill. App. 3d 733, 742-43, 666 N.E.2d 704, 711 (1996) (appellate court reviews de novo a trial court\u2019s denial of a section 2 \u2014 604.1 motion to amend). Section 2 \u2014 604.1 of the Code provides, in pertinent part, as follows:\n\u201cIn all actions on account of bodily injury ***, based on negligence, or product liability based on any theory or doctrine, where punitive damages are permitted[,] no complaint shall be filed containing a prayer for relief seeking punitive damages. However, a plaintiff may, pursuant to a pretrial motion and after a hearing before the court, amend the complaint to include a prayer for relief seeking punitive damages. The court shall allow the motion to amend the complaint if the plaintiff establishes at such hearing a reasonable likelihood of proving facts at trial sufficient to support an award of punitive damages.\u201d 735 ILCS 5/2 \u2014 604.1 (West 1996).\nIn determining whether plaintiffs met their burden of establishing a reasonable likelihood of proving facts at trial sufficient to support an award of punitive damages, we are guided by what our supreme court stated in Loitz v. Remington Arms Co., 138 Ill. 2d 404, 414-16, 563 N.E.2d 397, 401-02 (1990):\n\u201cPunitive, or exemplary, damages are not awarded as compensation, but serve instead to punish the offender and to deter that party and others from committing similar acts of wrongdoing in the future. [Citations.] Because of their penal nature, punitive damages are not favored in the law. [Citations.] Appropriately enough, the initial decision whether punitive damages may be imposed in a particular case in this State is a matter normally reserved to the trial judge. [Citations.]\nDescribing the circumstances in which an award of punitive damages is appropriate, this court in Kelsay v. Motorola, Inc., [74 Ill. 2d 172, 186, 384 N.E.2d 353, 359 (1978),] stated:\n\u2018It has long been established in this State that punitive or exemplary damages may be awarded when torts are committed with fraud, actual malice, deliberate violence or oppression, or when the defendant acts willfully, or with such gross negligence as to indicate a wanton disregard of the rights of others [citation], Where punitive damages may be assessed, they are allowed in the nature of punishment and as a warning and example to deter the defendant and others from committing like offenses in the future. [Citation.]\nSee also Restatement (Second) of Torts \u00a7 908(2) (1979) (\u2018Punitive damages may be awarded for conduct that is outrageous, because of the defendant\u2019s evil motive or his reckless indifference to the rights of others\u2019).\n*** It must be recognized, however, that \u2018[n]egligence is not the same as wantonness\u2019 [citation], and that \u2018[p]unitive damages are not awarded for mere inadvertence, mistake, errors of judgment and the like, which constitute ordinary negligence\u2019 [citation], \u2018Since the purpose of punitive damages is not compensation of the plaintiff but punishment of the defendant and deterrence, these damages can be awarded only for conduct for which this remedy is appropriate \u2014 which is to say, conduct involving some element of outrage similar to that usually found in crime. The conduct must be outrageous, either because the defendant\u2019s acts are done with an evil motive or because they are done with reckless indifference to the rights of others.\u2019 [Citation.] In this context, willful and wanton misconduct \u2018 \u201capproaches the degree of moral blame attached to intentional harm, since the defendant deliberately inflicts a highly unreasonable risk of harm upon others in conscious disregard of it.\u201d \u2019 [Citation.]\u201d\nJudged in accordance with these standards, the evidentiary material before the trial court at the time it denied plaintiffs\u2019 section 2 \u2014 604.1 motion did not establish conduct on defendants\u2019 part rising to the level of wrongdoing necessary to justify an award of punitive damages. We agree with the trial court, which stated, in pertinent part, as follows in denying plaintiffs\u2019 motion:\n\u201cAccording to the uncontroverted evidence submitted by the defendant[s], [General Motors] sold 364,575 J-cars in the 1996 model year: 268,585 Cavaliers and 95,990 Pontiac Sunfires. The 31 prior incidents of which [General Motors] received notice represent approximately .008% of the total production of 1996 Cavaliers and Sunfires, or one accident for every 11,760 vehicles sold. Although no figures were presented to the court, utilizing the same analysis of number of prior incidents to miles driven by those same vehicles would result in an infinitesimal percentage. Either meager percentage could not have put [General Motors] on notice that the 1996 Chevrolet Cavaliers and Pontiac Sunfires had a defect which would cause the inadvertent deployment of the vehicle\u2019s air bag in circumstances similar to the incident of November 6, 1996.\u201d\nSee Loitz, 138 Ill. 2d at 420, 430, 563 N.E.2d at 404, 408 (reversing award of punitive damages where 94 prior accidents reflected about 0.003% of production and \u201ceven smaller percentage\u201d of uses (gun)); Kopczick v. Hobart Corp., 308 Ill. App. 3d 967, 974-75, 979, 721 N.E.2d 769, 776, 779 (1999) (reversing award of punitive damages where 30 prior incidents reflected roughly 0.5% of production and 0.0000007% of estimated number of uses (cuts of meat)). Accordingly, we conclude that the court did not err by denying plaintiffs\u2019 section 2 \u2014 604.1 motion to amend their complaint to add a prayer for punitive damages.\nL. Plaintiffs\u2019 Claim That the Trial Court\u2019s Cumulative Errors Denied Them a Fair Trial\nLast, plaintiffs argue that the trial court\u2019s cumulative errors denied them a fair trial. Given our resolution of the aforementioned alleged errors, we conclude that the cumulative error doctrine does not apply to this case. See People v. Bradley, 220 Ill. App. 3d 890, 904-OS, 581 N.E.2d 310, 320 (1991) (holding that the cumulative error doctrine did not apply where the \u201cfew errors [that] occurred at trial\u201d did not prejudice the defendant).\nIII. CONCLUSION\nFor the reasons stated, we affirm the trial court\u2019s judgment.\nAffirmed.\nAPPLETON, J., concurs.", "type": "majority", "author": "JUSTICE STEIGMANN" }, { "text": "JUSTICE MYERSCOUGH,\nspecially concurring in part and dissenting in part:\nI agree that the court correctly allowed into evidence data downloaded from the SDM and the related testimony. However, I respectfully disagree with the majority\u2019s opinion affirming the trial court\u2019s sua sponte striking plaintiff\u2019s expert\u2019s opinion on causation. This court found Page \u201c \u2018did not employ knowledge and application of principles of science beyond the ken of the average juror\u2019 \u201d 332 Ill. App. 3d at 784 and, therefore, struck Page\u2019s testimony on causation and instructed the jury to disregard it. The majority affirmed on this issue but went on to point out that a jury does not need expert testimony to help it decide whether an inadvertently deployed air bag caused a driver to lose control of her car. This reasoning is circular. The majority affirms the trial court\u2019s finding that defendant was not an expert, but then states expert testimony on causation is not necessary to determine whether an air bag may cause a driver to lose control of her car.\nFirst, I believe expert testimony on this issue may be persuasive and certainly can assist the trier of fact in understanding the evidence. Page was a mechanical engineer with 35 years of experience in the aerospace industry. Page\u2019s testimony was based on everything he reviewed in this case, including General Motors\u2019 documents, previous inadvertent deployments, the report of road conditions, and witnesses\u2019 accounts, to reach the conclusion of inadvertent deployment and then causation. The causation opinion cannot be reached without the deployment opinion. These opinions cannot be isolated.\nPage\u2019s qualifications are certainly greater than this court\u2019s to determine causation in this case. At trial, defendants could cross-examine Page on the bases for his opinion and thereby discredit that opinion. But, for the court to emphasize the plaintiffs expert\u2019s lack of qualifications by striking on its own motion part, perhaps the most crucial part, of the plaintiffs testimony is an abuse of discretion and reversible error. The trial court\u2019s action here was highly prejudicial to plaintiffs case.\nDefendants had filed their motion in limine in October 2000, months prior to trial, seeking to block Page\u2019s testimony. In November 2000, the trial court denied the motion. It was not until the middle of the jury trial that the court barred the testimony, surprising plaintiff and leaving plaintiff without a causation expert.\nThe majority finds this error harmless because the jury did not reach the question of causation, deciding only that the air bag did not deploy. However, in the absence of any of plaintiff\u2019s causation testimony, the jury logically could find the air bag did not deploy.\nMoreover, if expert testimony is not necessary on causation, why cannot defendants, or anyone else for that matter, testify to their opinion on causation? This is not testimony on the ultimate issue in the case \u2014 was defendant negligent? \u2014 so Page should have been permitted to testify. Moreover, Page was plaintiffs only expert who testified to causation. Plaintiffs reconstruction expert did not give an opinion regarding the air bag actually being deployed:\n\u201c \u2018[t]he Cavalier appeared to be driven by a person who could have been stunned, but not certainly out of control\u2019; and (2) he could think of no other cause for Danielle\u2019s lack of reaction to the approaching hazard of Reed\u2019s step van.\u201d 332 Ill. App. 3d at 776.\nA vehicle appearing to be driven by one who could have been stunned, and being unable to think of no cause for lack of driver reaction, hardly states an opinion that an air bag deployment caused the accident. The lack of an expert on causation and the impact of striking Page\u2019s testimony were clearly prejudicial and a surprise to plaintiffs. The trial court clearly abused its discretion and committed reversible error.", "type": "concurring-in-part-and-dissenting-in-part", "author": "JUSTICE MYERSCOUGH," } ], "attorneys": [ "William T. Cacciatore (argued) and Eileen J. McCabe, both of Rockford, for appellants.", "David M. Heilbron, Frank M. Hinman, Monty Agarwal, and Christina M. Wheeler, all of McCutchen, Doyle, Brown & Enersen, L.L.E, of San Francisco, California, and Joseph E. O\u2019Neil (argued), Francis J. Grey, Jr., and Jennifer M. Brooks, all of Lavin, Coleman, O\u2019Neil, Ricci, Finarelli & Gray, of Philadelphia, Pennsylvania, for appellees." ], "corrections": "", "head_matter": "DEBRA L. BACHMAN, as Mother and Legal Guardian of the Estate and Person of Danielle L. Bachman, a Disabled Person, et al., Plaintiffs-Appellants, v. GENERAL MOTORS CORPORATION et al., Defendants-Appellees.\nFourth District\nNo. 4 \u2014 01 \u2014 0237\nArgued April 23, 2002.\nOpinion filed July 29, 2002.\nWilliam T. Cacciatore (argued) and Eileen J. McCabe, both of Rockford, for appellants.\nDavid M. Heilbron, Frank M. Hinman, Monty Agarwal, and Christina M. Wheeler, all of McCutchen, Doyle, Brown & Enersen, L.L.E, of San Francisco, California, and Joseph E. O\u2019Neil (argued), Francis J. Grey, Jr., and Jennifer M. Brooks, all of Lavin, Coleman, O\u2019Neil, Ricci, Finarelli & Gray, of Philadelphia, Pennsylvania, for appellees." }, "file_name": "0760-01", "first_page_order": 778, "last_page_order": 826 }