Life after Voykin v. Estate of DeBoer, a plaintiff’s perspective
By Christopher M. Norem
Tort Law,
March 2004
Prior to the Illinois Supreme Court's holding in Voykin v. Estate of DeBoer, there was a significant split among the various state district courts on the so-called "same part of the body rule" (which presumed that a previous injury was automatically relevant simply because it was to the same part of the body) and how that affected the admissibility of evidence of prior injuries to the same part of a plaintiff's body.
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