In December 2019, we addressed, for the first time in more than two decades, the issue of the admissibility of physicians' testimony as to their custom and practice, also known as habit evidence. See Evidence of Custom and Practice, NYLJ (Dec. 3, 2019), p. 3. We are drawn back to that subject by two recent Appellate Division decisions that provide new insights into the admissibility and applicability of such evidence.