Jury’s Comparative Fault Verdict Upheld in Eastern Tennessee Auto Collision Case: Miller v. Moretz

The Court of Appeals of Tennessee at Knoxville has affirmed a jury’s award in a car wreck case. In Miller v. Moretz, a 72-year-old driver was involved in an automobile accident with another motorist. According to disputed testimony offered at trial, the man’s vehicle was either backing up into a driveway or preparing to back up when a collision occurred between the rear corner of his vehicle and the driver’s side of the other vehicle. Following the crash, the elderly man and his wife filed a negligence lawsuit against the other driver over the personal injuries each allegedly sustained in the collision. In their complaint, the plaintiffs claimed that the defendant motorist failed to yield the right of way, failed to maintain a proper lookout, drove at an excessive rate of speed, followed their vehicle too closely, and more. The defendant responded by stating he was operating the vehicle in a prudent fashion. He also claimed the plaintiff failed to yield and violated the legal limitations placed on backing up a vehicle by Section 55-8-163 of the Tennessee Code.

Before trial, the defendant driver filed a motion in limine asking the court to prohibit the plaintiffs from introducing evidence related to his use of prescription medication at the time of the collision. Such a motion is normally considered by a judge while outside of a jury’s presence at the beginning of a trial. It is used to determine whether certain evidence may be introduced for the jury’s inspection. The defendant driver argued before the trial judge that evidence regarding his use of prescription medication should not be used for impeachment purposes because such evidence would have a prejudicial effect on him. Since the plaintiffs’ lawsuit did not allege the defendant driver was somehow impaired at the time of the traffic wreck, the court granted the defendant’s motion and excluded evidence related to his drug use.

Following trial, a jury found the defendant motorist 10 percent at fault for the car accident. Additionally, the jury held the plaintiff driver 90 percent responsible for the crash and valued his wife’s damages at zero. Since Tennessee is a modified comparative fault state, this means the plaintiffs were not entitled to recover any compensation for their alleged injuries. Under modified comparative fault rules, an accident victim may not recover for his or her harm if a jury or judge decides the injured party was at least 50 percent responsible for the accident. The plaintiffs responded to the jury’s verdict by filing a motion for a new trial. Their motion was denied, and the couple appealed their case to the Court of Appeals of Tennessee at Knoxville.

On appeal, the plaintiffs argued that the trial court committed error when it granted the defendant’s motion in limine and when it refused to order a new trial. According to the Knoxville court, the trial court’s exclusion of any evidence related to the defendant’s prescription drug use was within its discretion because the value of the evidence to the finders of fact was low, while the likelihood that allowing the information would result in prejudice was high. Additionally, the court said any error related to the exclusion of the evidence for impeachment purposes was harmless because multiple witnesses offered testimony that supported the defendant driver’s claims. Finally, the court stated the jury award could not be overturned because there was sufficient material evidence to support the jury’s decision regarding fault in the case.

If you were injured in a Blount County car accident, the knowledgeable lawyers at the Hartsoe Law Firm, P.C. may be able to help. Please give our hardworking attorneys a call at (865) 524-5657 or contact us through our website.

Additional Resources:

Miller v. Moretz, Tenn: Court of Appeals 2014

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