Federal District Court Denies Defendant’s Motion to Exclude Doctor’s Testimony in Tennessee Tractor-Trailer Accident Case

In an east Tennessee truck accident case, the plaintiff has the burden of proof. This means that he or she must provide proof sufficient to convince the jury, by a preponderance of the evidence, that the defendant’s failure to act in a reasonably prudent manner was the proximate cause of his or her injuries. In most cases, this evidence includes the testimony of one or more physicians who are qualified to explain to the jury the nature and extent of the plaintiff’s physical injuries, treatment, and limitations. If the defendant disagrees with the qualifications of the plaintiff’s proposed expert witness(es), a motion to exclude the testimony may be filed. The trial court will then rule upon the motion, and whichever party is aggrieved thereby may eventually seek the review of an appellate court regarding the decision.

Facts of the Case

In a recent federal court case, the plaintiff filed suit against the defendants, seeking compensation for personal injuries he allegedly suffered in a rear-end collision involving his van and their tractor-trailer. The defendants filed a motion to exclude the testimony of the plaintiff’s treating physician and medical expert, arguing that the doctor did not state in his deposition that he was serving as an expert witness, the doctor did not examine any documents other than the plaintiff’s medical records and was not aware of any facts related to the accident, the doctor’s report lacked a method of reasoning as to his conclusion that the accident at issue caused the injuries complained of by the plaintiff, the doctor did not connect his experience to his conclusions, and/or the doctor did not take into account possible causes of the plaintiff’s injuries other than the accident.

The plaintiff responded that, even if the doctor’s report was “technically deficient,” it would not be appropriate for the court to exclude it because any alleged failure to disclose it was harmless in that it did not prejudice the defendants.

Decision of the Court

The United States District Court for the Eastern District of Tennessee at Chattanooga denied the defendants’ motion to exclude the doctor’s testimony. The court began by acknowledging that Federal Rule of Evidence 702 sets forth the standard for expert testimony: a witness who has “sufficient knowledge, skill, experience, training, or education” may give an opinion if his or her knowledge will help the trier of fact determine a fact in issue and/or better understand the evidence offered by the parties at trial, the expert’s opinion is based on sufficient facts, the proffered testimony is based on reliable methods, and the expert witness has applied the established principles to the appropriate facts. The trial court judge serves as the “gatekeeper” is determining whether a particular expert’s opinion should be admitted at trial.

Here, the court found that the doctor’s report demonstrated that he relied upon information gained during his medical treatment of the plaintiff, along with his education, training, and experience as an orthopedic surgeon, and that there was no indication that he employed an unusual method as a treating physician. Insomuch as his testimony was reliable and would assist the jury in deciding the factual disputes regarding the plaintiff’s injuries, the court found that there was no reason to exclude his expert testimony at trial.

To Talk to a Truck Accident Attorney

Accidents involving big trucks can cause serious personal injuries and even wrongful death. To talk to a lawyer about filing a claim for medical expenses, pain and suffering, and other damages caused by the driver of an 18-wheeler, call the experienced Knoxville truck accident legal team at the Hartsoe Law Firm. You can schedule an appointment by calling us at 865-524-5657.

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