Maryland Personal Injury Blog
In some in Maryland car accident cases, the evidence presented to a jury may have a significant impact on the outcome of the trial. In a February 12, 2019 opinion, the Court of Special Appeals of Maryland considered whether evidence of prior auto accident injuries was irrelevant or prejudicial to a plaintiff seeking underinsured motorist benefits from his auto insurance company.
The plaintiff in the case was rear-ended at low speed while his vehicle was stopped at a red light. Later that day, the plaintiff sought medical treatment for pain in his neck, back, knees, hips, elbows, and for nausea and headaches. He underwent an MRI, which revealed preexisting, degenerative changes to his neck and back. Over the next several years, the plaintiff intermittently received medical treatment for the pain.
The plaintiff filed a lawsuit for underinsured motorist benefits against his insurer, as the policy limits of the at-fault motorist did not cover all of his damages. Before trial, the plaintiff filed a motion to prevent the jury from learning about his other claims and injuries in six previous car accidents, as well as the one that occurred after the accident at issue in the case. The trial court, however, allowed the defendant to introduce evidence of the accidents that had caused injuries to the same parts of the plaintiff’s body as the crash at issue. The jury ultimately awarded the plaintiff over $28,000, but it only covered a fraction of his medical expenses. As such, the plaintiff sought review from the appeals court, seeking the full amount of his damages.
In Maryland, a court may admit relevant evidence, but cannot admit any evidence that is irrelevant. Nevertheless, the court has considerable discretion to exclude relevant evidence if its probative value is substantially outweighed by the danger of unfair prejudice. On appeal, the plaintiff asserted that the other accidents were irrelevant, and that even if they were relevant, their value at trial was substantially outweighed by the danger of unfair prejudice to him.
In reviewing the evidence, the appeals court noted that the defendant sought to establish that the plaintiff was attempting to recover damages for injuries other than the ones he had suffered in the accident at issue. In particular, the injuries from the other accidents supported the testimony of the defendant’s expert witness, who had opined that they were not attributable to the low-speed, rear-end accident at issue in the case.
In these circumstances, the court found that the evidence of trauma caused by other car accidents was relevant to explain the defendant’s theory that the other accidents were the source of the plaintiff’s pain. The appeals court went on to find that the lower court had not erred by allowing the relevant evidence, as it had significant discretion to do so and there was support for its ruling. Accordingly, the amount of damages awarded to the plaintiff by the jury was affirmed.
At Foran & Foran, P.A., our Maryland injury lawyers can represent victims of car and truck accidents against insurance companies as well as the negligent drivers that caused their injuries. If you are seeking guidance about a personal injury or medical malpractice case, we are ready to listen. Call (301) 441-2022 or contact us online to request a free consultation with one of our experienced attorneys today.
More Blog Posts:
Maryland Plaintiffs File Personal Injury Lawsuit After Rear-End Car Accident, Maryland Personal Injury Blog, published October 24, 2018
Maryland Court Orders Insurance Company to Cover Loss for Wrongful Death Claims Arising Out of Car Accident, Maryland Personal Injury Blog, published August 17, 2016