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Niec (D) operated a beauty shop. Doutre (P) suffered head and facial injuries because of a bleach and color treatment given by D without a pretreatment patch test. At trial, D was not permitted to testify about the standard of care observed by beauty shops in the Flint area. P was awarded $10,000. D's motion for a new trial was granted, but the new trial was limited to the question of liability. P appealed; the trial court's evidentiary ruling was correct. D appealed; it was error to limit the new trial to the issue of liability.

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