In Hall v. Grosvenor, 267 Ill. App. 119 (1932), the plaintiff appealed a directed verdict for the defendant, a surgeon who had left a sponge in her body after an operation. The court stated that "the failure to remove the sponge, standing alone and unexplained, was prima facie evidence of negligence." Hall, 267 Ill. App. at 121. No expert testimony was needed to prove that this lapse was "improper." Hall, 267 Ill. App. at 122. Thus, the court held only that the failure to remove the sponge was prima facie evidence that the doctor had been negligent. The court recognized that the doctor might be able to avoid liability by showing that the mistake was not caused by carelessness on his part. In doing so, the court relied on Olander v. Johnson, 258 Ill. App. 89 (1930). Hall, 267 Ill. App. at 122-23.