Shelksohn v. Yeh
Nevada Supreme Court
281 P.3d 1218 (2009)
In a wrongful-death suit against Dr. Yeh (defendant) alleging he improperly administered an epidural without waiting for a test-dose reaction, nurse Clark testified the patient seized within ten seconds but could not confirm what dosage Yeh gave; another nurse, Spector, would have testified Clark told her in an elevator afterward that Yeh gave "a big bolus" all at once, but Clark said she didn't recall that conversation, and the trial court excluded Spector's testimony because Shelksohn (plaintiff) never specifically asked Clark about the elevator conversation's substance.
Whether courts require a proper evidentiary foundation to admit evidence of prior inconsistent statements for impeachment purposes, laid by asking the witness specifically about the statement's substance, time, place, and to whom it was made.