Waiver Rule in Medical Malpractice: Unobjected-to Standard-of-Care Testimony (Even If Not Tendered as Expert) Must Be Considered on Sufficiency Review

Case: Mary Margaret Upchurch and Rickie Upchurch v. Adam I. Lewis, M.D. and Jackson Neurosurgery Clinic, PLLC
Court: Supreme Court of Mississippi (En Banc)  |  Date: August 6, 2026

1. Introduction

This medical-malpractice appeal arose from a 2016 surgery performed by neurosurgeon Dr. Adam I. Lewis at Merit Health Rankin. Mary Margaret Upchurch and her husband, Rickie (collectively, the Upchurches), alleged that Dr. Lewis and Jackson Neurosurgery Clinic, PLLC, negligently proceeded with surgery using incompatible spinal cord stimulator components, failed to obtain proper informed consent for additional procedures performed mid-surgery, and failed to timely address postoperative neurological decline—culminating in a hematoma and lasting lower-extremity paralysis/weakness.

A Rankin County jury returned a defense verdict. The circuit court denied the Upchurches’ post-trial motions for judgment notwithstanding the verdict (JNOV) and for a new trial. The Court of Appeals reversed, concluding the verdict lacked evidentiary support because (in its view) Dr. Lewis’s standard-of-care testimony should not have been considered—he was not tendered or accepted as an expert witness.

On certiorari, the Supreme Court of Mississippi reinstated the jury verdict, holding that because the Upchurches did not contemporaneously object to Dr. Lewis’s testimony on the “not-qualified-as-expert” ground, any such complaint was waived; thus, the testimony remained part of the evidentiary record and could support the verdict.

2. Summary of the Opinion

A. Disposition

  • Cause No. 2023-CT-01296: The Court of Appeals was reversed; the circuit court’s judgment on the defense verdict was reinstated and affirmed; denial of JNOV and new trial was affirmed.
  • Cause No. 2024-CT-00396: The Court of Appeals’ affirmance of the circuit court’s order assessing appellate record-designation costs to Dr. Lewis/Jackson Neurosurgery was affirmed (no certiorari petition was filed as to this cause).

B. Core Holdings

  • Waiver controls the evidentiary universe on appeal: where a party fails to object at trial that a witness was not qualified/tendered as an expert, the party waives the issue, and the testimony remains evidence for sufficiency/weight review.
  • Sufficiency and weight: considering all admitted evidence in the light most favorable to the defense, substantial evidence supported the jury’s no-negligence verdict; the verdict was not against the overwhelming weight of the evidence.
  • Directed verdict on nursing staff liability: conflicting evidence created a jury question on whether nursing communication failures contributed to the outcome; denial of directed verdict was proper.
  • Jury instructions: challenged instructions were not reversible error when the instructions were read as a whole, including plaintiff-offered instructions allowing liability on any one of multiple negligence theories and defining proximate cause as potentially multiple.

3. Analysis

3.1. Precedents Cited (and How They Drove the Outcome)

A. Waiver / Contemporaneous Objection

The decision’s fulcrum is Evans v. City of Aberdeen, 926 So. 2d 181 (Miss. 2006). In Evans, the Court held that where no objection is made at trial to a party’s “failure to qualify their witness” as an expert, the issue is waived and the appellate court may not discount the testimony when evaluating the case.

Evans itself relies on the broader contemporaneous objection principle stated in Mallard v. State, 798 So. 2d 539 (Miss. 2001), and Smith v. State, 530 So. 2d 155 (Miss. 1988): an error is preserved for appellate review only through timely trial objection; otherwise, it is waived.

Applying Evans, the Supreme Court concluded the Court of Appeals “improperly excluded” Dr. Lewis’s unobjected-to testimony about standard of care and compatibility/mixing of device components. Once admitted without objection, that testimony “became part of the evidence in the case” and could sustain a defense verdict.

B. JNOV / Sufficiency Standards

The Court framed sufficiency review through Miss. Transp. Comm'n v. United Assets, LLC, 188 So. 3d 508 (Miss. 2016), and Adcock v. Miss. Transp. Comm'n, 981 So. 2d 942 (Miss. 2008): JNOV is reviewed de novo, and denial is affirmed if “substantial evidence” supports the verdict. It also invoked InTown Lessee Assocs., LLC v. Howard, 67 So. 3d 711 (Miss. 2011), quoting Spotlite Skating Rink, Inc. v. Barnes ex rel. Barnes, 988 So. 2d 364 (Miss. 2008): evidence is viewed in the light most favorable to the verdict winner, with all favorable inferences.

C. Plaintiff’s Burden and the Jury’s Freedom to Reject Plaintiff’s Experts

The Court reiterated, via Johnson v. Pace, 122 So. 3d 66 (Miss. 2013), and Palmer v. Biloxi Reg'l Med. Ctr., Inc., 564 So. 2d 1346 (Miss. 1990), that the plaintiff bears the burden to prove duty, breach, proximate causation, and injury. For the jury’s role in weighing and rejecting even expert testimony, the Court relied on Thompson v. Dung Thi Hoang Nguyen, 86 So. 3d 232 (Miss. 2012): the jury may accept all, part, or none of any witness’s testimony, including experts.

D. “Subjective Standard of Care” Concerns Distinguished

The Upchurches cited Bickham v. Grant, 861 So. 2d 299 (Miss. 2003), where a jury instruction improperly suggested a physician’s “best judgment” could define the standard of care—an impermissibly subjective formulation. The Court distinguished Bickham because no such “best judgment” instruction was given here. Instead, the jury received an objective national standard-of-care instruction, and Dr. Lewis testified as to what he did and why it met that objective standard.

E. New Trial / Weight of the Evidence

For weight review, the Court again used Miss. Transp. Comm'n v. United Assets, LLC and Johnson v. St. Dominics-Jackson Mem'l Hosp., 967 So. 2d 20 (Miss. 2007): a new trial is warranted only when the verdict is so contrary to the overwhelming weight of the evidence that it would sanction an unconscionable injustice. The Court emphasized the jury’s role in resolving conflicting testimony through Williams v. State, 391 So. 3d 193 (Miss. 2024), quoting Wilson v. State, 343 So. 3d 1041 (Miss. 2022), and reiterated deference to credibility determinations via Williams v. State, 391 So. 3d 1151 (Miss. 2024), quoting McFadden v. Miss. State Bd. of Med. Licensure, 735 So. 2d 145 (Miss. 1999).

F. Directed Verdict Standard

On the directed verdict issue, the Court cited Forbes v. Gen. Motors Corp., 935 So. 2d 869 (Miss. 2006), quoting Entergy Miss., Inc. v. Bolden, 854 So. 2d 1051 (Miss. 2003): if the evidence and reasonable inferences present a jury question, a directed verdict is improper.

G. Jury Instruction Review “As a Whole”

For instruction review, the Court relied on Moody v. State, 202 So. 3d 1235 (Miss. 2016), quoting Bailey v. State, 78 So. 3d 308 (Miss. 2012), and referencing Boyd v. State, 47 So. 3d 121 (Miss. 2010): instructions are reviewed collectively, and no reversal occurs if they fairly announce the law. It also cited Smith ex rel. Smith v. Miss. Coast OB/GYN, 325 So. 3d 723 (Miss. Ct. App. 2021), quoting Fred's Stores of Miss., Inc. v. M&H Drugs Inc., 725 So. 2d 902 (Miss. 1998), for the same “as a whole” principle.

H. Proximate Cause in Medical Malpractice

Addressing “the” vs. “a” proximate cause, the Court referenced elements stated in Smith v. Hardy Wilson Mem'l Hosp., 300 So. 3d 991 (Miss. 2020), quoting Norman v. Anderson Reg'l Med. Ctr., 262 So. 3d 520 (Miss. 2019): plaintiffs must show the breach was the proximate cause or proximate contributing cause, typically through expert testimony. The Court found any potential ambiguity was cured because plaintiff’s instructions included “proximate and contributing cause” language and expressly stated there may be more than one proximate cause.


3.2. Legal Reasoning

A. The Court of Appeals’ “evidence subtraction” was legally improper

The Supreme Court did not decide whether Dr. Lewis should have been qualified as an expert to opine on standard of care in the first instance. Instead, it treated the issue as one of preservation: because the Upchurches did not object on the ground that he was not tendered/accepted as an expert, the appellate court could not retroactively remove that testimony from the sufficiency analysis.

B. Once the testimony stayed in, substantial evidence existed

With Dr. Lewis’s unobjected-to testimony included, the evidentiary record supported a defense view:

  • Dr. Lewis testified that mixing manufacturers’ components was common “off label,” and he had used Boston Scientific batteries with St. Jude leads successfully for decades.
  • He explained the intraoperative incompatibility as stemming from a lead he described as “flimsy,” “corroded,” and “bent,” and he testified it would not fit “any” adapter/battery/pulse generator.
  • The Court highlighted that the Upchurches’ own expert (Dr. Narlin Beaty) agreed that if a lead was misshaped or damaged, it was “no longer appropriate to be implantable into any device.”

That combination created a reasonable basis for jurors to conclude the Upchurches did not meet their burden on breach and/or causation, even in the face of contrary expert opinions about device compatibility and preparation.

C. Deference to the jury on conflicts and credibility

The Court’s approach is a classic appellate restraint posture: where testimony conflicts, the jury resolves it. The Court rejected the idea that a “mountain” of plaintiff evidence compels reversal when the defense has legally admissible evidence supporting an alternative inference.

D. Remaining issues: directed verdict and jury instructions

After reinstating sufficiency, the Court addressed additional issues:

  • Nursing staff liability: testimony from nurse expert Stephen Furman and from Dr. Beaty was sufficient to create a fact question whether nursing communication failures contributed to delay in recognition/treatment of neurological decline.
  • Instruction D-14 (Jury Instruction No. 9): although it used “each and every element” and referred to proving “negligence claims,” any potential confusion was cured by the Upchurches’ own instruction (Jury Instruction No. 10) expressly allowing liability if any one of four alternative negligence theories was proven and by the proximate-cause instruction stating there may be more than one proximate cause.
  • Standard-of-care instruction (Jury Instruction No. 4): the Court held it was adequate because another instruction (plaintiff’s) connected breach of the standard of care to negligence.

3.3. Impact

A. Appellate review must assess sufficiency using the evidence actually admitted

The most significant practical consequence is procedural: appellate courts may not reframe sufficiency by excluding admitted testimony on an unpreserved qualification objection. If evidence came in without contemporaneous objection, it remains part of the sufficiency/weight calculus.

B. Trial practice: qualification objections must be timely and specific

For malpractice litigants, the case is a cautionary template. If a defendant physician (testifying as a fact witness) begins offering opinions that sound like expert standard-of-care testimony, opposing counsel must object and articulate the basis (e.g., not tendered/qualified under applicable evidence rules). Waiting until appeal risks waiver.

C. Substance (not just procedure): defendant testimony can be outcome-determinative

Even where multiple plaintiff experts testify to breach, a defense verdict can stand if there is substantial contrary evidence admitted at trial—here, Dr. Lewis’s explanation of his practice and the alleged damaged lead, plus causation uncertainty. The decision reinforces that “battle of experts” outcomes belong to juries, not appellate reweighing.

D. Instruction drafting: “as a whole” review rewards coordinated instructions

The Court’s instruction analysis underscores the strategic reality that a party’s own instructions can cure (or dilute) objections to an opponent’s instruction. Here, plaintiff instructions explicitly set out alternative negligence theories (OR’d) and multiple-proximate-cause language, neutralizing claims that the defense instruction’s phrasing misled the jury.

4. Complex Concepts Simplified

  • JNOV (Judgment Notwithstanding the Verdict): a post-trial request asking the judge to overturn the jury’s verdict because, even viewing the evidence favorably to the verdict winner, no reasonable jury could have reached that verdict (a legal sufficiency test).
  • Motion for New Trial: asks the judge to order a new trial because the verdict is against the overwhelming weight of the evidence (a weight/credibility-sensitive inquiry, highly deferential to the jury).
  • Directed Verdict: requested during trial, asking the court to remove an issue from the jury because the evidence permits only one reasonable outcome.
  • Standard of Care (Medical Malpractice): the objective benchmark for what a minimally competent physician in the same field would do under similar circumstances—not what a particular doctor personally believed was best.
  • Proximate Cause / Proximate Contributing Cause: the required causal link between the breach and the injury; Mississippi recognizes that more than one cause can contribute to an injury.
  • Waiver by Failure to Object (Contemporaneous Objection Rule): if you do not object when the evidence is offered, you usually cannot complain about it on appeal; the testimony stays in the case and can support the verdict.
  • “Off label” use: using a product in a way not described in its labeling/directions-for-use. Off-label use may be common in medicine, but whether it meets the standard of care is a fact question typically resolved through expert testimony—unless the testimony comes in without objection, in which case the jury may consider it.

5. Conclusion

Upchurch tightens the procedural guardrails of Mississippi malpractice appeals: a party cannot win reversal by persuading an appellate court to disregard standard-of-care testimony that was admitted at trial without objection merely because the witness was not formally tendered as an expert. Anchored in Evans v. City of Aberdeen, the opinion confirms that preservation rules define what evidence exists for sufficiency review.

Substantively, the case reinforces jury primacy in resolving dueling accounts of medical decision-making, device compatibility, and causation. Practically, it serves as a trial-lawyer warning: when testimony crosses from fact narrative into expert opinion, the moment to object is when the testimony is offered—not after an unfavorable verdict.