Did the trial court abuse its discretion in refusing to allow Smith to introduce evidence that Jurgensen received financial benefits from collateral sources?
[¶16] Smith argues that because references to Jurgensen’s financial condition were made by both Jurgensen and his attorney, she should have been allowed to introduce evidence that Jurgensen received benefits from collateral sources. This argument is unpersuasive. [¶17] It is well settled under South Dakota law that “‘[t]otal or partial compensation received by an injured party from a collateral source, wholly independent of the wrongdoer, does not operate to reduce the damages recoverable from the wrongdoer.'” Moore v. Kluthe & Lane Ins. Agency, Inc., 89 SD 419, 434, 234 NW2d 260, 269 (1975) (quoting Swift & Company v. Gutierez, 76 Idaho 82, 277 P2d 559, 561 (1954)). Furthermore, a plaintiff’s collateral source of income “cannot be inquired into as part of a defendant’s case, because of the danger that the jury may be inclined to … reduce a damage award, when it learns that plaintiff’s loss is entirely or partially covered.” Moses v. Union Pacific R.R., 64 F3d 413, 416 (8thCir 1995).
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