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State v. Ingraham6/23/1998 uggested that " eferences to or implications of such interactions would be unduly prejudicial, confuse the issues, mislead the jury, and appeal solely to the jury's passion and prejudice." As it did with respect to Ingraham's motion to generally exclude evidence of the drugs detected in his system and found in his car, the District Court denied Ingraham's motion to exclude evidence of warnings about drug and alcohol interactions, concluding that evidence was relevant to the question of Ingraham's alleged negligence.
At trial, Ingraham objected to the proposed testimony of Michael Freeman, a pharmacist from the Family Health Pharmacy in Ronan. Ingraham opposed Freeman's plans to testify about warnings he had "given either to Mr. Ingraham directly or to patients generally about the dangers of librium and its use, either in conjunction with alcohol or with other prescription or nonprescription medicines." Ingraham sought to exclude the proposed testimony on several grounds. Ingraham first argued the proposed testimony was irrelevant in light of Hutchison's anticipated testimony that none of the drugs, either alone or in combination with alcohol, had any impairing effect upon Ingraham's ability to drive on the evening of the accident. Ingraham additionally argued that, even if relevant, the prejudicial effect of admitting evidence of warnings generally given in connection with the various medications in this case would "far exceed its probative value." In response, the State argued that the drugs detected in Ingraham's system and found in his car would be relevant to demonstrate Ingraham's negligence and that evidence of warnings generally given was relevant to demonstrate Ingraham's "gross negligence . . . in choosing to self-medicate with prescription drugs."
The District Court overruled Ingraham's objection to Freeman's proposed testimony. The court again reasoned that the question of whether Ingraham's use of the drugs, in conjunction with alcohol, "constitutes or is a component of gross negligence, is a fact question for the jury to decide," and concluded that evidence regarding warnings "is part of the evidence [the jury] need to make that determination."
A. Relevance
As we have with respect to the admissibility of evidence regarding Ingraham's drug use, we similarly conclude that whether evidence of warnings generally given with those medications is relevant, and thus admissible, depends upon the State's ability to demonstrate a link between Ingraham's alleged failure to abide by those warnings and the cause of the accident.
At trial, pharmacist Freeman testified as to warnings generally given with the medications at issue. Freeman was employed by the Family Health Pharmacy in Ronan, the pharmacy which dispensed the prescription bottle of Buspar found by Officer Roth in Ingraham's car. Freeman began his testimony by explaining his general duties as a pharmacist. For example, Freeman agreed that providing patients with information regarding "warnings or cautions about drug interactions" is "one of main functions," and proceeded to detail the various methods he generally employs to impart that information. Freeman then testified that he had provided Ingraham with medications in the past, including the prescription bottle of Buspar. Freeman then read aloud from the auxiliary label affixed to the bottle of Buspar which cautioned patients to " btain medical advice before taking nonprescription drugs which may affect the effect of this medication." Then, despite the fact that absolutely no traces of Buspar were present in Ingraham's system on the night of the accident, Freeman explained Buspar's use and general effects, recognizing that although "m
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