In Maniglia v. Carpenter, two men were involved in a nighttime car accident on Interstate 95 in Florida in 2009. The accident was purportedly caused when the left front portion of one car struck the right rear corner of another vehicle while changing lanes. Although the driver who was changing lanes and his passenger asserted that the collision was minor, the other driver complained that it was a serious accident.
Following the crash, the allegedly hurt motorist sought chiropractic treatment for neck and back pain. An x-ray showed no injuries except for “normal wear and tear.” As a result, the chiropractor did not place any work restrictions on the injured driver. About one month later, the injured man collided with a car while driving a golf cart. The man was apparently thrown to the ground as a result. He was also arrested following an altercation with law enforcement authorities who responded to the incident. Despite this, the injured driver apparently failed to disclose the subsequent accident to his chiropractor. The hurt man also sought treatment from a surgeon, who suggested the man undergo surgery after examining magnetic resonance images taken following the golf cart incident.
Next, the injured driver filed a personal injury lawsuit against the driver of the vehicle involved in the I-95 collision. At trial, the injured man sought to exclude all evidence related to the golf cart accident. The man argued the resulting prejudice would outweigh the probative value of the information under Section 90.403 of the Florida Statutes. The trial court agreed with the man’s claim that the golf cart accident was too interwoven with his subsequent arrest to be introduced at trial. As a result, the trial court granted the man’s motion and excluded the entirety of the golf cart crash evidence.
During trial, the defendant motorist was allowed to offer evidence that the injured man participated in a golf tournament and played bumper cars with another cart near the first hole. The court also allowed evidence related to the man’s level of intoxication to be introduced. Despite this, jurors did not hear evidence regarding the golf cart crash, the subsequent altercation with police, or the hurt man’s failure to notify his health care providers about the incident. The jury ultimately returned a verdict of more than $180,000 in favor of the injured driver. In response, the defendant motorist filed an appeal with Florida’s Third District Court of Appeals.
On appeal, the court first stated the statute forbids evidence that would result in unfair prejudice to be introduced at trial. According to the appellate court, however, the information that was excluded addressed both the injured man’s credibility and causation related to his purported injuries. The court stated this evidence was significantly probative. In addition, the court ruled that the potential for any unfair prejudice did not outweigh the probative value of the information and said the issue could have been addressed through jury instructions regarding intervening causes and subsequent harm. As a result, the court held that the trial court’s order granting the man’s motion to exclude the golf cart accident evidence was erroneous.
Since the injured man benefited from the trial court’s error and failed to show that the error did not contribute to the jury’s verdict, Florida’s Third District Court of Appeals reversed and remanded the case for a new trial.
If you were injured in a South Florida motor vehicle collision, you should discuss your right to recover financial compensation with a seasoned personal injury lawyer. To speak with a dedicated Miami personal injury attorney soon, call the knowledgeable advocates at Friedman, Rodman & Frank, P.A. at (305) 448-8585 or contact us online today.
Maniglia v. Carpenter, Fla: Dist. Court of Appeals, 3rd Dist. 2015
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