On April 5, 2018, the Virginia Supreme Court issued Williams v. Swenson, No. 170538. It rejected a “continuing objection” to prospective closing argument references as “waived,” because counsel: (1) “was not clear as to whether it addressed argument concerning foreseeability pertaining to the standard of care or causation or both,” ; id. at 4, (2) failed “to renew the objection specifying how counsel’s remarks moved outside the scope of permissible argument,” id.; and (3) “failed to request relief in the manner of a curative instruction or motion for mistrial”. Id. at 5. The Williams medical malpractice appear also rejected a disputed puffered jury instruction as an incorrect statement of law. Id. at 3.