Texas Supreme Court Reviews Evidence of Causation in Truck Accident Case

trucks-on-the-road-1449684A plaintiff in a personal injury case must establish “causation” between the accident or event and the injuries sustained. More specifically, under Texas law, the plaintiff must prove that the defendant’s conduct caused an event that in turn caused the plaintiff to suffer injuries. Furthermore, when an injured party seeks to recover medical expenses, he or she must provide evidence of the conditions that generated the expenses and show that those conditions were caused by the accident. All of this must be taken very seriously. The absence of proof of causation can serve to defeat a plaintiff’s claim for damages. In order to ensure that your personal injury complaint complies with applicable law, you are strongly encouraged to contact an experienced injury attorney from the East Texas area as soon as possible after an accident.

A recent Texas Supreme Court case addressed the issue of causation and the importance of “relevant” evidence in a case. In JLG Trucking, LLC v. Garza, the plaintiff (Lauren Garza) was rear-ended by an 18-wheeler driven by an employee of JLG Trucking. Although the plaintiff did not go to the hospital after the accident, she testified that she went to an emergency clinic to have x-rays taken and that she later saw an orthopedic surgeon for complaints of back and neck pain. The doctor prescribed physical therapy. Approximately three months later, after completing 11 weeks of therapy, the plaintiff got into a second car accident, from which she was transported to a hospital near the scene. While at the hospital, the plaintiff complained of pain in her head, neck, and chest. After two MRIs, she was found to have several herniated discs in her neck, and she underwent spinal fusion surgery. She now has reduced mobility in her neck and the potential for surgery in the future.

The plaintiff brought an action against JLG, asserting that its employee’s negligence proximately caused her injuries. She sought damages for physical pain, past and future medical costs, mental anguish, physical impairment, loss of earning capacity, and disfigurement. Her doctor provided testimony that the first accident was the cause of her herniated discs. The defendant, on the other hand, attempted to provide expert testimony that the plaintiff’s pain and suffering was due to a degeneration of her discs (and not a trauma-related injury). The defendant also attempted to introduce evidence of the later accident as alternatively causing her injuries. The plaintiff made a motion to exclude any evidence of the second accident, contending that there was no causal connection between the injuries and the second accident.

The trial court granted the motion to exclude the evidence. On appeal, JGL argued that the evidence of the second accident was relevant and that its exclusion amounted to harmful error. The court of appeals affirmed the decision, concluding that the trial court did not abuse its discretion. The highest court in the State reversed the decision, concluding that evidence of the second accident was relevant to the issue of causation:  that is, whether JLG’s negligence caused the plaintiff’s damages. The case was remanded to the trial court for a new trial.

Accidents involving cars, trucks, and other motor vehicles can vary a great deal in terms of the chain of events surrounding a crash, as well as any resulting injuries sustained. The importance of carefully assessing your case with an experienced injury attorney cannot be overstated. Earl Drott is an injury attorney with more than 25 years of experience representing victims in auto accident cases in the East Texas area. For a free consultation, call (903) 531-9300.

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