## Facts

- Linda J. Wrobleski sued Dr. Nora de Lara (a gynecologist) for medical malpractice after a June 6, 1994 laparoscopy during which Wrobleski’s small intestine was perforated, causing leakage, infection, pain, and corrective surgery.
- The parties presented competing expert testimony on whether de Lara met the applicable standard of care; the dispute was primarily a credibility contest between experts.
- Wrobleski called Dr. Lilling as an expert witness.
- On cross-examination, defense counsel asked how much money Lilling earned in 1995 from providing expert-witness services.
- Lilling testified that less than 20% of his total income came from expert-witness work but refused to disclose the dollar amount, asserting privacy concerns because the figure could be used to estimate his total income.
- The trial court ruled the witness should answer the question but did not compel compliance by contempt or other sanction; the jury observed the exchange.
- The jury returned a defense verdict finding no negligence, and judgment was entered for de Lara.

## Issues

1. Whether the trial court abused its discretion by permitting cross-examination of the plaintiff’s expert about the dollar amount earned in a single year from expert-witness testimony, given asserted privacy concerns and claimed unfair prejudice.

## Decision

- The Court of Appeals of Maryland affirmed the judgment for de Lara.
- The court held it was not error to allow questioning of an expert witness about the amount earned in a particular year from expert-witness services.
- The court concluded the trial court acted within its discretion in allowing the inquiry as relevant to bias and credibility.

## Legal Principles

- Cross-examination to show a witness’s bias, interest, or motive—particularly an expert’s financial interest in expert-witness work—is generally permitted and is a proper form of impeachment.
- A witness’s total personal income may implicate stronger privacy concerns, but the amount derived from expert-witness services is more directly tied to potential bias and may be inquired into.
- The scope of cross-examination on impeachment and bias is committed to the trial court’s discretion and will be reversed only for prejudicial abuse of that discretion.
- A jury may consider a witness’s refusal to answer a permissible, relevant question when assessing credibility.

## Conclusion

The court upheld the defense verdict, ruling that permitting cross-examination of a medical expert about annual income from expert testimony was a permissible means of probing bias and did not constitute prejudicial abuse of discretion.


Wrobleski v. de Lara, 727 A.2d 930 (Md. 1999)