THOMAS, Judge.
Ronald Tune brought this action against Synergy Gas Corporation (Synergy) for severe burns and other personal injuries he sustained in a propane gas explosion and fire. The jury assessed one hundred percent fault to Synergy and found damages to be $2,850,-000.00. The damage figure was adjusted for settlement amounts and prejudgment interest, and the trial court entered a judgment of $2,812,556.84 in favor of Tune. Synergy appealed and the court of appeals affirmed. Synergy then sought transfer to this Court. We affirm in part and reverse and remand in part.
I.
Granby Gas set up a system for the retail sale of propane at 71 Truck Stop. Granby Gas retained ownership of the equipment it installed with the exception of the 1000 gallon storage tank. Defendant Synergy purchased Granby Gas Company and acquired its equipment on May 12, 1988. On May 25, 1988, Synergy sold and delivered approximately 300 gallons of propane to 71 Truck Stop. After the delivery, there were approximately 840 gallons in the tank.
Plaintiff Ronald Tune was employed by Tim Heifner in Heifner’s business, Satellites Unlimited, which sells and services satellite television equipment. On June 24, 1988, He-ifner and Tune had a job updating an existing satellite system. The job entailed cutting and welding angle iron. That morning, Tune was preparing the equipment for the job. He opened the valve to the propane cylinder for the cutting torch, smelled nothing, and assumed the tank was empty. Tune then loaded the welder and the propane and oxygen cylinders for the torch into a trailer. Heifner and Tune proceeded to the 71 Truck Stop to have the propane cylinder filled.
A portable propane cylinder should only be filled to eighty percent of capacity. The only way to determine how much propane is in a cylinder of the type Heifner and Tune had is to weigh it. However, the attendant at 71 Truck Stop did not weigh the cylinder. The attendant filled the cylinder until the pump motor “bogged out” or “couldn’t run anymore” and said he was giving Heifner and Tune a good deal. As a result, the cylinder was overfilled to nearly one hundred percent capacity.
Heifner and Tune then drove the forty-five to fifty miles to their job site and arrived at approximately 11:00 a.m. They began upgrading the system and were working approximately twenty feet downwind from their trailer where the propane tank was located. Heifner first made some cuts with the propane torch and then began welding. When Heifner struck the third welding rod, there was an explosion. The two were surrounded by flames.
Tune suffered partial thickness burns to approximately forty percent of his body. He [13]*13received treatments for approximately forty days including twenty-six days of hospitalization. His treatments included hydrotherapy for which he was placed in a saltwater and antiseptic solution twice a day for cleaning of his burns. This procedure includes debridement during which dead tissue is scrubbed off with a brush. He was required to wear a body suit for one year following his hospitalization.
Tune’s injuries are permanent. He has to use special soaps and lotions. Noises scare him; his nerves are “pretty shot;” he has trouble sleeping; he is sensitive to the sun, heat, cold, detergents, and other substances; his skin changes colors and tears easily; he has severe reactions to insect bites and stings; he has scarring; and he has a feeling of tightness in his skin. His ability to work and to engage in recreational activities has been restricted.
The pleadings alleged alternative theories of strict liability and negligence. The negligence allegations included negligent overfilling of the cylinder and negligent failure to train. The strict liability counts included defective and unreasonably dangerous product and failure to warn. The case was ultimately submitted only on strict liability-failure to warn.
Expert testimony established that the overfilling of the cylinder combined with the expansion of the gas with the heat of the day caused propane to leak out of the cylinder. The propane, being heavier than air, settled near the ground and was carried toward the men by a slight breeze. The propane was ignited by the arc from the welder.
Propane is an odorless gas. An odorant, usually ethyl mercaptan, is added to propane to warn of the presence of propane gas. The effectiveness of ethyl mercaptan can decrease through several factors including oxidation with rust on the inside of a cylinder and adsorption on various surfaces such as the ground. Also, because propane is heavier than air, propane may be at a greater concentration at ground level before there is a sufficient concentration to detect the odo-rant at the level of a person’s nose.
Heifner and Tune each testified that they did not smell the propane odorant before the explosion. Tune testified that he knew what propane smelled like but that he did not know its chemical properties. There was expert testimony that the circumstances surrounding the explosion and fire were consistent with there having been a significant decrease in odorant concentration in the gas. Synergy provided no warning of the risk that ethyl mercaptan might not be effective to provide warning of the presence of gas and provided no training to the employees of 71 Truck Stop before the accident.
II.
We first address Synergy’s point that the trial court should have directed a verdict in favor of Synergy because Tune failed to make a submissible case on product liability-failure to warn. Synergy contends that the product did not reach Tune without a substantial change in condition, there was no expert testimony that the product was defective or unreasonably dangerous, and Tune failed to show causation because the evidence fails to establish that a warning would have prevented the accident.
An appellate court views the evidence in the light most favorable to the plaintiff to determine whether a submissible case was made when reviewing the denial of a motion for a directed verdict. Winn-Senter Const. v. Katie Franks, Inc., 816 S.W.2d 943, 944 (Mo.App.1991). The elements of a cause of action for strict liability-failure to warn are: (1) defendant sold the product in question in the course of defendant’s business; (2) the product was unreasonably dangerous at the time of sale when used as reasonably anticipated without knowledge of its characteristics; (3) the defendant did not give adequate warning of the danger; (4) the product was used in a reasonably anticipated manner; and (5) plaintiff was damaged as a direct result of the product being sold without an adequate warning. Nesselrode v. Executive Beechcraft, Inc., 707 S.W.2d 371, 382 (Mo. banc 1986); MAI 25.06 (4th ed. 1991).
[14]*14A.
Synergy argues that the propane gas was substantially changed from the condition in which it was sold when the cylinder was overfilled at the truck stop and that Synergy should therefore be relieved of liability. Tune put on evidence that Synergy failed to warn of the dangers of overfilling or of the possibility that the odor in ethyl mercaptan might be ineffective to warn of the presence of propane. The reason for not overfilling, the danger of expansion and leakage rather than giving the customer more propane than the customer bought, was one of the things Tune argued that Synergy should have explained. There was no evidence that overfilling the cylinder changed the characteristics of the gas or the odorant. These characteristics were present when the propane was sold by Synergy. There was no evidence that the overfilling in any way affected the likelihood that ethyl mercaptan might not be effective to warn of the presence of propane. The dangerous product, the propane gas, was not modified.
B.
Synergy concedes that under current Missouri law expert testimony is not necessarily required to establish product defect or unreasonable danger. See Nesselrode, 707 S.W.2d at 378; Wadlow by Wadlow v. Lindner Homes, Inc., 722 S.W.2d 621, 625 (Mo.App.1986). Synergy urges this Court to adopt a rule requiring expert testimony to establish product defect or unreasonable danger in every design defect or failure to warn case.
In this case there was expert testimony that the effectiveness of ethyl mercaptan can decrease, that Synergy gave no warning of this characteristic, that propane is very dangerous without knowledge of this characteristic, and that the circumstances were consistent with there having been a significant decrease in odorant concentration. The jury had guidance and was not left to speculation and conjecture.
Given this information, a reasonable jury would have no problem in determining that propane gas is unreasonably dangerous and should be able to make this determination, particularly where there was no warning at all. A jury would have little trouble discerning that no warning was not an adequate warning. We decline to adopt the overly-inelusive rule proposed by Synergy in this case.
C.
There are two separate requirements of causation in a failure to warn case: (1) the product for which there was no warning must have caused plaintiffs injuries, and (2) the plaintiff must show that a warning would have altered the behavior of those involved in the accident. Arnold v. Ingersoll-Rand Co., 834 S.W.2d 192, 194 (Mo. banc 1992). Synergy argues that Tune did not show the second requirement.
If there is sufficient evidence from which a jury could find that the plaintiff did not already know the danger, there is a presumption that a warning will be heeded. See id. Tune testified that he knew what propane smelled like but that he did not know its chemical properties. He stated that he assumed the cylinder was empty the morning of the accident because he smelled nothing when he opened the valve. From this testimony, the jury could find that Tune did not know of the danger that the odorant might not be effective to indicate the presence of propane under some circumstances. This question gives rise to the presumption that a warning would have been heeded. In this instance, the term “presumption” is used to mean “makes a prima facie case,” i.e., creates a submissible ease that the warning would have been heeded. Synergy’s claim to the contrary is without merit.
D.
Looking at the facts in the light most favorable to the plaintiff, we find that Tune made a submissible case in strict liability failure to warn. This point is denied.
III.
Appellant, Synergy Gas, next complains that the trial court erred in admitting evidence that it did not conduct any training sessions at 71 Truck Stop until eighteen [15]*15months after the accident. Synergy argues that such evidence is highly prejudicial and is not relevant because it merely proves carelessness or negligence by Synergy following the accident and that post-accident conduct was not causal of the plaintiffs injuries. Synergy cites several locations in the transcript where it claims such evidence was admitted, but the only evidence that remotely resembles the evidence complained of in this point of error in Synergy’s brief to which there was any objection is one question and answer in the deposition of Joseph Waddell. Waddell became a branch manager of the Synergy facility at Granby in December 1988, approximately six months after the plaintiff was injured. The question and answer, and two follow-up questions and answers, read to the jury, were as follows:
Q: Now, since you didn’t become the Branch Manager until December of ’88, did you — when did you go over it [conduct a safety training session] with these people?
A: I’m not sure exactly. I believe I held a safety meeting there probably in December of ’89, or something like that.
Q: Okay, it wasn’t prior to June 24,1988?
A: No.
Q: Do you know of any other representative of Synergy Gas who may have given them a safety course or safety instructions with regard to the handling of LP gases prior to June 24, 1988?
A: Not to my knowledge.
Defendant made timely objection to the reading of the first question on the grounds that anything that occurred after the date of the accident is not relevant. Plaintiffs counsel argued that he was not trying to show the nature of the training that occurred but was attempting to show that the first training Synergy did at the truck stop after they purchased the business was in December 1989, approximately eighteen months after the accident. The trial court admitted the evidence stating: “It appears to me that this is relevant in that it tends to show that there was no training given to the C.A.M. people before the accident. It is relevant in that respect, so I overrule the objection.”
An item that is relevant for one purpose but not for another is nevertheless admissible. McCormick on Evidence, § 59 (4th ed. 1992). In the context of this question and answer, the reference to training in December 1989 is simply the witness’ method of communicating the idea that there was no training before, at or near the time of the accident because it was, in fact, eighteen months later when the first training occurred. The thrust of the evidence is further emphasized by the two follow-up questions, both of which refer to and emphasize the date of the accident, June 24,1988. If defendant wished to further emphasize the limited purpose of this evidence, it was free to request an instruction limiting the jury’s use of this evidence. See id. No such request was made. The trial court was clearly within its discretion in admitting this evidence for the limited purpose for which it was admitted.
Synergy also complains that plaintiff improperly argued this evidence in closing argument by asking the jury to use it as evidence of negligence in the eighteen months following the accident rather than for the limited purpose for which it was admitted. It is true that plaintiffs counsel was running a substantial risk of error when he argued: “Nobody [from Synergy Gas] concerned with safety or about safety went to that truck stop for 18 months after they took over.” However, there was no objection of any type to this argument, no motion for a mistrial and no motion to strike, so nothing is preserved for appeal. It is particularly important in closing argument that objections be preserved so that the trial court will have an opportunity to correct this type of error without causing a mistrial. It would have been relatively simple and entirely understandable for the trial court to explain to the jurors that the failure to instruct the truck stop personnel in safety during the eighteen months following the accident had nothing to do with this accident and that they should not consider this contention in arriving at their verdict. The important point is that the failure of the defendant to object and preserve this potential error is fatal to this point on appeal.
[16]*16The court of appeals analyzed, and the parties briefed, the admissibility of this evidence on the theory of subsequent remedial measures. The issue of the admissibility of evidence of remedial measures is presented when a plaintiff offers evidence of some precaution or preventive measure taken by a defendant after an accident for the purpose of the jury comparing the remedial measure with the absence thereof at the time of the accident and concluding that the defendant was at fault for failing to take the remedial measures prior to the accident. To raise such an issue in this case would require detailed evidence that the training sessions were at least in part devoted to subjects related to the. cause of this accident. We pointed out above that the mention of safety training sessions in this evidence was merely to denote the end of the period of time before and after the accident when no training sessions occurred. The evidence does not begin to disclose the kind of information that would be necessary for the jury to evaluate whether the type of training that occurred beginning in December 11989 would have been of any usefulness in avoiding the accident had the training occurred prior to June 1988. More importantly, the court did not admit the evidence for this purpose. As pointed out above, this evidence was admitted for a very limited purpose. Even considering plaintiffs argument, to which no objection was made, this evidence was not offered or used as evidence of remedial measures. We decline to evaluate it on that basis. This point is denied.
IV.
A.
We next consider Synergy’s point of error concerning plaintiffs closing argument on damages. Synergy claims the trial court was in error in overruling defendant’s objection and allowing plaintiffs counsel to argue a specific amount of total damages for the first time in the final portion of plaintiffs closing argument.
Plaintiffs counsel devoted most of the initial portion of his closing argument to liability issues. Then, at the end of this argument, he talked about the damages the plaintiff had sustained. He summarized the amounts of the actual out-of-pocket past expenses, primarily medical and loss of wages, which he explained to' the jury totaled $54,419.28. Plaintiffs counsel then told the jurors that they would have to put down a figure for pain and suffering and for diminishment of quality of life; that the jury had evidence that plaintiff had a life expectancy of 35 years and that he will have future medical expenses, future loss of earnings, future pain and suffering and future loss of quality of life, all for the next 35 years. He closed this portion of his argument by telling the jurors that they would have to total that all up to arrive at the amount to award the plaintiff, but he made no suggestion or request for a specific amount of total damages.
Defendant’s closing argument was devoted totally to issues of liability. The closest reference defendant’s counsel made to damages was that “Mr. Tune received bad injuries” and that he (defendant’s counsel) did “not want to downplay” the injuries.
Plaintiffs counsel then returned for his final closing argument and, after a few miscellaneous comments concerning liability, said: “Let’s talk about damages.” He proceeded to suggest specific amounts for various damages, including $2,000,000.00 for past pain and suffering, $40,000.00 for past dimin-ishment of quality of life, $6,006.00 for lip balm for the rest of his life, and $248,400.00 for loss of future earnings. He then discussed future pain and suffering, for which he asked $1,040,000.00, and $20,000.00 for future loss of quality of life. He asked for a total verdict of $3,368,825.29. When it became clear he was going to ask for specific amounts of money, but before he mentioned any particular amount, defendant made the following objection:
[DEPENDANT’S ATTORNEY:] Objection. Your Honor, may we approach the bench?
(Counsel approached the bench and the following proceedings were had out of the hearing of the jury:)
[DEFENDANT’S ATTORNEY:] Your Honor, I think it’s improper for him to [17]*17mention an amount, since he didn’t mention it in the first part of his argument.
[PLAINTIFF’S ATTORNEY:] I talked about damages.
[DEFENDANT’S ATTORNEY:] You did not mention an amount.
[PLAINTIFF’S ATTORNEY:] Sure, I did. I talked about filling in the amounts.
[DEFENDANT’S ATTORNEY:] He did not mention an amount. And he can’t—
[PLAINTIFF’S ATTORNEY:] Certainly I can.
[THE COURT:] Objection’s overruled; go ahead.
The party with the burden of proof (usually the plaintiff) splits the time allowed for closing argument and argues first and last; the other party (usually the defendant) argues in the middle. The plaintiffs final closing argument, often called rebuttal,1 is normally limited to a rebuttal argument. Votrain v. Illinois Terminal R. Co., 268 S.W.2d 838, 844 (Mo. banc 1954). This means, at a minimum, that the plaintiffs counsel can answer and cover whatever subject matters were covered by defense counsel in closing argument. However, as the rules have developed in Missouri, plaintiffs counsel is not limited merely to rebutting the argument that defense counsel made but, in addition, may cover any subject that the plaintiff covered in the initial portion of the closing argument, even if the defendant did not argue this subject. This expansion of the true rebuttal rule is supported by the rationale that the reason for limiting plaintiffs counsel to rebuttal in the final portion of the closing argument is to afford defendant an opportunity to answer any argument the plaintiff makes. If the argument in issue is covered by the plaintiff in the initial part of the closing argument, then the defendant had an opportunity to answer the argument, and that meets the requirements of the rule.
This approach (determining what is proper rebuttal by what the plaintiff argues in the initial part of the closing argument) developed from Shaw v. Terminal Railroad Ass’n of St. Louis, 344 S.W.2d 32 (Mo.1961). In Shaw, plaintiffs counsel argued liability only and then closed the initial portion of his closing argument by telling the jury that he would have some additional matters to discuss when he came back. In response to this, defendant’s counsel approached the bench and advised the court and plaintiffs counsel that if plaintiffs counsel intended to cover new matters not previously covered, and particularly damages, he should cover them in his initial argument so that defense counsel would have an opportunity to answer. Defense counsel served notice he intended to object to any new points in plaintiffs final argument. The court overruled the objection. Plaintiffs counsel made no further argument at this time, and defense counsel then made his argument but did not argue damages. Plaintiffs counsel returned and, over objection, made an extensive damage argument, which he concluded by asking for a verdict of $25,000.00. Id. at 36. This Court held that the party having the burden of proof may not, after full notice and warning, withhold all argument on damages in the initial portion of the closing argument and then make such an argument and request a specific amount of money in the final portion of the closing argument.2 In reversing and remanding for a new trial, we said that counsel for plaintiff will be required to state the essential points in the initial closing argument, at least to the extent that the defendant may fairly answer them. Id. at 37.
[18]*18Shaw has been cited so extensively for the proposition that the plaintiff cannot withhold all argument on damages in the initial portion of the closing argument and then argue damages in the final portion of the argument that the Missouri rule as to what is proper rebuttal is commonly inaccurately stated by referring only to what the plaintiff argued in the initial portion of the closing argument. On the few occasions when the Missouri courts have faced the issue of what is proper rebuttal under circumstances in which defendant has argued damages in defendant’s closing argument, the courts have referred to this circumstance as a waiver of the general rule that looks to plaintiffs initial closing argument to determine what is proper rebuttal. See Barrett v. Morris, 495 S.W.2d 100, 105 (Mo.App.1973); Weinbauer v. Berberich, 610 S.W.2d 674, 678 (Mo.App.1980). It is more accurate and helpful to state the complete rule in the affirmative, i.e., in the final portion of the closing argument a plaintiff can argue anything that plaintiff argued in the initial portion of the closing argument3 and rebut anything that the defendant argued in defendant’s portion of the closing argument.4
Applying this rule to the present case, although the defendant did not argue damages in his portion of the closing argument, the plaintiff did make a limited damage argument as a part of his initial portion of the closing argument. Thus, it becomes necessary to examine the damage arguments by plaintiff to determine whether the argument plaintiffs counsel made in the final portion of his closing argument was closely enough related to the damage argument made in the initial portion of his closing argument that it constituted proper argument.
Of course, it is obvious that in applying the foregoing rule to the specific facts of any case, there is an infinite spectrum of issues as to what constitutes the same subject that was previously argued or what constitutes a new and therefore improper argument. The Missouri courts, as well as most other courts, have recognized that the practical application of a specific rule must be left to the broad discretion of the trial court. In Shaw, we said, “It is not practical to lay down a hard and fast rule governing all cases, in all their varying circumstances....” Shaw, 344 S.W.2d at 37. “Despite the general rule, the means of applying it in the handling of arguments cannot be made fixed and exact because the facts and circumstances of cases vary widely and the application must be somewhat flexible.” Misch v. C.B. Contracting Co., 394 S.W.2d 98, 102 (Mo.App.1965).
Despite the obvious broad discretion granted to the trial court, there will be circumstances when this discretion has been abused and the appellate court will step in and overturn the trial court’s ruling. In certain litigation, the issues will fall naturally and accurately into certain categories. For example, the division between liability arguments and damage arguments in most civil litigation is fairly obvious; if there is no argument on damages in either the initial portion of plaintiff’s closing argument or in [19]*19the defendant’s closing argument, allowing argument by plaintiff in the final portion of the closing argument over objection would likely be an abuse of discretion. This rule was not violated in this situation because plaintiff argued damages in the initial portion of his closing argument.
However, a similar but more specific rule, which is not subject to the discretion of the trial court, has developed in the Missouri cases. In Goldstein v. Fendelman, 336 S.W.2d 661 (Mo.1960), the Court recognized a significant limitation upon counsel’s right to ask for specific amounts of damage by stating:
[ W]hile we recognize that the trial court has considerable discretion in the matter of arguments of counsel, we consider it unfair and improper to permit plaintiffs counsel to do this [ask for specific amounts of damages] for the first time in his closing argument when defendant’s counsel has made no argument as to amount.
Id. at 667. The Court in Goldstein determined no objection had been made on that ground. However, the Court removed from the trial court’s discretion the issue of when asking for a specific amount of total damages will be proper in plaintiffs final portion of the closing argument, i.e., only when plaintiff has asked for a specific amount of total damages in the initial portion of closing argument or defendant has made a damage argument that justifies plaintiff asking for a specific amount of total damages may plaintiff argue a specific amount of total damages in the final portion of the closing argument. In the present case, defendant made no substantial argument with respect to damages and did not discuss specific amounts. The only specific amount of damages mentioned by the plaintiff in the initial portion of the opening argument was $54,419.28 for actual, out-of-pocket past expenses for medical and loss of wages.
It should be obvious from even the slightest consideration of the rationale for the rule that plaintiffs mention of actual damages of more than $54,000.00 in the initial portion of his argument does not lay the foundation for his specific request for over $3,000,000.00 total damages in the final portion of his argument. The opportunity for the defendant to answer the $54,000.00 argument as to special damages is certainly not an opportunity to answer the plaintiffs specific request in the final portion of his closing argument for a total verdict in excess of $3,000,000.00:
The Missouri court of appeals has had further occasion to consider under what circumstances a request for a specific amount of damages will be proper in the final portion of the plaintiffs closing argument. In Hart v. Forbes, 633 S.W.2d 90 (Mo.App.1982), the plaintiff, in the initial portion of the closing argument, discussed the difference between special and general damages and explained to the jury’ that his special damages totaled $3,229.50. Id. at 93. He discussed pain and suffering, anxiety caused by the accident, nightmares the plaintiff had, and a permanent leg injury caused by one leg being one-half inch longer than the other. Id. at 94. However, he did not ask for a specific amount of total damages for these injuries. In plaintiffs final argument, counsel began by saying, “[W]e’re not going to ask you for any particular amount of money, ...” but then asked a rhetorical question: “Is sixty years worth sixty thousand dollars?” Id. The defendant’s objection that this was improper rebuttal argument was sustained. Id. In .affirming the trial court, the court of appeals, succinctly summarized and followed the rule from Goldstein as follows:
From Goldstein, it is obvious that the matter of final argument is within the sound discretion of the trial judge, but there is a prohibition against plaintiffs counsel arguing a dollar amount in the final portion of closing argument (absent reference in the initial phase and/or comment relative thereto by defense counsel) on the basis of fairness to both parties.
Hart, 633 S.W.2d at 95.
In Clark v. Kansas City Area Transp. Authority, 673 S.W.2d 55 (Mo.App.1984), the defendant complained on appeal of
the trial court’s refusal to permit appellant to argue a dollar amount for damages when she had not argued such in the initial part of her closing argument [the defen[20]*20dants did not comment on the dollar amount in their argument].
That plaintiff herein failed to request a specific sum or suggest a dollar amount in her initial closing argument is not in dispute. The defendant likewise did not comment on a dollar and cents figure. Plaintiff may not, therefore, in the final portion of closing argument inject an amount into the case when defense counsel made no argument as to amount. Goldstein v. Fendelman, 336 S.W.2d 661, 667 (Mo.1960); Votrain v. Illinois, 268 S.W.2d 838, 844 (Mo. banc 1954).
Id. at 59. The court of appeals also quoted from Shaw, 344 S.W.2d at 37, in holding that the trial court did not err in denying plaintiffs request to argue a specific amount of damages in the final portion of plaintiffs closing argument. Id.
In Weinbauer, 610 S.W.2d at 677-79, the court of appeals let the trial court’s ruling stand, which allowed the plaintiff to ask for a specific amount of money in the rebuttal portion of his argument even though he did not ask for a specific amount of money in the initial portion of his closing argument, but, unlike the present case, the defendant argued damages in closing argument. Weinbauer cites and relies upon Barrett, 495 S.W.2d at 104-05, and Midwest Library Service, Inc. v. Structural Systems, Inc., 566 S.W.2d 249, 251-52 (Mo.App.1978), where plaintiffs were allowed to mention a specific amount of damages in the final portion of their closing argument because the defendant had argued damages in closing argument. Id. at 678.
Not only is the rule set forth in Goldstein well supported in case precedents, but it is also supported by sound reasoning and understandable rationale. When one lawyer who is not present at a trial asks another lawyer who was present to describe the plaintiffs damage closing argument, it will almost always be described by relating what amount of damages the attorney asked for. If it is not described in this manner, the follow-up question will likely be, “How much damages did the plaintiff ask for?” This is because a plaintiffs damage argument is largely characterized by the decision of whether to ask for a specific amount of damages and, if so, how much. These are not easy decisions. The plaintiff may ask for such an unreasonably large and unexpected amount of damages so as to turn the jury off. Or, the jury may feel that by suggesting a specific amount the plaintiffs counsel is infringing upon their function. If the plaintiff does suggest a specific amount of damages, the decision of how the defendant will respond can be difficult and very important. Should the defendant treat the plaintiffs demand as being so large as to be ridiculous, or should it be ignored? Should the defendant suggest an amount of his own, which in many instances will become a floor for the verdict, or should defendant argue the case as if it will be decided for defendant on liability and not discuss damages? All of these are difficult and critical decisions for both the plaintiff and the defendant, but they are decisions that each party should have an opportunity to make if, in fact, the damage argument progresses to the point of a discussion of specific amounts.
A decision to ask for a specific amount is an easily and accurately ascertainable occurrence in any trial. It consistently signals an intensifying of the damage argument. It generally presents the same type of problems in every lawsuit. It is an occasion in which fairness demands an opportunity for the defendant to respond and a circumstance to which the defendant cannot intelligently respond until he first hears the plaintiffs demand. Under these circumstances, it makes eminent sense to have a definite rule, as Missouri does, which is clear, concise and understandable. Missouri’s rule has been set out with clarity for the past thirty-four years in Goldstein. The plaintiff in this ease proceeded directly into the teeth of the rule over the specific objection of the defendant who was raising precisely the correct rule. Under these circumstances, we have no choice but to find that the trial court erred in allowing plaintiff to ask for a specific amount of total damages for the first time in the final portion of his closing argument.
Having found error, we must determine whether the error was prejudicial. One line [21]*21of cases supports the proposition that argument on the issue of damages can be prejudicial only if there is an excessive verdict. See, e.g., Smith v. Courier, 531 S.W.2d 743, 748 (Mo. banc 1976); McCormick v. Smith, 459 S.W.2d 272, 278 (Mo.1970); Chambers v. Kansas City, 446 S.W.2d 833, 841 (Mo.1969); Conlon v. Roeder, 418 S.W.2d 152, 162 (Mo. 1967); Faught v. Washam, 329 S.W.2d 588, 602 (Mo.1959). But cf. Sparks v. Auslander, 353 Mo. 177, 182 S.W.2d 167, 173 (1944) (argument as to damages not prejudicial unless it had some effect on the amount of damages) (emphasis in original). On the other hand, in Lester v. Sayles, 850 S.W.2d 858 (Mo. banc 1993), this Court stated that the party responsible for error relating to argument on the issue of damages “should be charged with a presumption that the error was prejudicial”. Id. at 864. The error in Lester occurred when the trial court complied with the jury’s request during deliberations for a chart, which was not in evidence, showing the specific amounts of damages plaintiffs attorney had asked for in closing argument.
In Shaw, this Court dealt specifically with the issue of whether error that improperly deprives defendant of a damage rebuttal argument is only prejudicial if the damages are excessive. In rejecting this argument we said:
The issue here is not merely whether the verdict was thus rendered excessive, as plaintiff now contends. No one can say what verdict this jury might have returned if the arguments had proceeded in the regular course, and if defendant’s counsel had been permitted to answer the argument on injuries and damages. We hold that this error would necessitate a reversal, independent of other points raised.
Shaw, 344 S.W.2d at 37.
We believe the rule in Lester is the better rule. There is an enormous variance in the size of the verdict that a rational jury may return and still not be excessive, particularly in a personal injury action. All of the various factors that inure in a jury verdict potentially have an impact upon the amount of the verdict any given jury returns in a given case. These would include the evidence, the applicable law, and the argument on damages. Any error in any of these factors in a jury trial will be prejudicial to the defendant if it results in an increase in the amount of the verdict, even though such increased verdict may not be excessive. However, it is usually impossible to determine whether or how much such an error contributes to the verdict. Given the fact such errors have occurred, it is more reasonable to assume that they contributed to an increase in the damages than to assume the contrary. This, in part, is the rationale for the decision in Lester.
In reviewing verdicts to determine if they are excessive, appellate courts overturn only those verdicts that are obviously out of line and grossly improper. In Breeding v. Dodson Trailer Repair, 679 S.W.2d 281 (Mo. banc 1984), we said: “To obtain relief on the basis of excessive verdict, the defendants must demonstrate that the verdict is glaringly unwarranted so as to shock the conscience of the court.” Id. at 286. The test applied by appellate courts is not fine tuned and should not be; the appellate courts generally defer to the jury’s decision as to the amount of damages. This is as it should be because the determination of the amount of damages is a task that lay juries are particularly able to perform. As a result, it is fairly unusual for an appellate court to find a jury’s determination to be excessive. This further strengthens the argument for finding prejudice even though there has been no finding of an excessive verdict. First, if we make enforcement of the rules concerning evidence and argument related to damages dependent upon the uncommon finding that the damages are excessive, we neutralize the impact of those rules in the majority of cases because we will only be enforcing the rules on the rare occasion where damages are found to be excessive. Second, if we are going to defer to the jury’s determination of damages, we must be assured that the jury’s finding was reached under a set of rules that guarantee fairness to all parties concerned under all circumstances. To argue that the verdict is not excessive because the rules were followed and that the rules do not have to be followed unless the verdict is excessive is to engage in [22]*22a circular argument. To avoid this pitfall we must enforce the rules if we are going to encourage appellate courts to defer to the jury’s determination of damages. If we do not enforce the rules, then we cannot rely on the jury’s damage assessment. Determination of damages is something that courts do not do well. This function is better performed by a jury, and courts should not second-guess a jury’s determination when it can be avoided.
The rule in Lester is also in keeping with the common practice in other areas of the law. For example, error in “[t]he exclusion of evidence is presumed prejudicial unless otherwise shown.” McMillin v. McMillin, 633 S.W.2d 223, 226 (Mo.App.1982). See also Reed v. Reed, 101 Mo.App. 176, 70 S.W. 505, 506 (1902) (“The error is presumed to be prejudicial where it is not shown to be harmless.”). Though not always so clearly stated, this is the general rule when reviewing the admission or exclusion of évidence. See e.g., State Farm Mut. Auto. Ins. Co. v. Allen, 744 S.W.2d 782, 787 (Mo. banc 1988) (no prejudice in erroneous exclusion of testimony when later witness gave same testimony); Hansome v. Northwestern Cooperage Co., 679 S.W.2d 273, 276 (Mo. banc 1984) (no reversible error in excluding cumulative evidence). In accordance with this rule, “[e]r-ror committed in a criminal case is presumed prejudicial, but that presumption is not conclusive and may be rebutted by the facts and circumstances of the case.” State v. Dale, 874 S.W.2d 446, 452 (Mo.App.1994).
We adopt the rule derived from Lester that the party responsible for error relating to argument on the issue of damages is charged with a rebuttable presumption that the error was prejudicial. Cases holding that error in argument on the issue of damages is prejudicial only if there is an excessive verdict are overruled to the extent they are inconsistent with this opinion.
In the present case, we presume that the trial court’s error was prejudicial. The plaintiff has not shown otherwise. In fact, the proximity of the jury’s determination of damages to the specific amount plaintiffs counsel requested in the final portion of his closing argument supports the presumption of prejudice.
The jury’s verdict of $2,850,000.00, even considering the plaintiffs serious injuries, is a very substantial verdict. Even in this day and age when million dollar verdicts are not uncommon, in the parlance of the ball diamond, this is a “big league” verdict. Certainly the size of this verdict forecloses us from avoiding a remand on the basis that the error was not prejudicial. The prejudicial effect may have been cured if defense counsel had been given an opportunity to reply to the increased specific amount, but we find no requirement that defendant’s counsel request this uncommon remedy. See, e.g., Sullivan v. Hanley, 347 S.W.2d 710, 716 (Mo.App.1961). Thus, the trial court committed prejudicial error in overruling the defendant’s objection and allowing the plaintiff to ask for a specific amount of total damages for the first time in his final closing argument.
This error goes only to damages and does not affect liability. We reverse and remand for a new trial on damages only. “No new trial shall be ordered as to issues in which no error appears.” Rule 84.14
V.
Synergy’s final point is whether the trial court erred in not finding that the verdict was excessive and either (1) ordering a new trial because the verdict was the result of passion and prejudice arising from the admission of the testimony concerning the 1989 training session or Tune’s final closing argument concerning damages, or (2) ordering a remittitur because the verdict exceeded fair and reasonable compensation for Tune’s injuries. Because we reverse and remand for a new trial on damages, we need not address this issue.
VI.
We reverse the judgment as to the damage award but affirm the judgment in all other respects. We remand to the trial court for a new trial on the issue of damages.
COVINGTON, C.J., and PRICE, LIMBAUGH and ROBERTSON, JJ., concur.
[23]*23HOLSTEIN, J., concurs in part and dissents in part in separate opinion filed.
BENTON, J., concurs in opinion of HOLSTEIN, J.