Texas Court Discusses Exclusion of Expert Testimony in Car Accident Cases

In car accident cases, it is not uncommon for a defendant to argue that a collision was low-impact and, therefore, could not have caused the plaintiff’s harm. Some defendants will go so far as to retain a biomechanical engineer to support such assertions. While defendants have the right to rely on expert testimony, such testimony must be relevant and helpful to the jury; otherwise, it will be precluded, as shown in Jesus Jimenez Escamilla, Jr., v. Gabriela Estrada, (No. 05-23-00236-CV) a recent ruling issued by a Texas court.  If you suffered injuries in a car accident, it is smart to talk to a Texas car accident lawyer as soon as possible.

History of the Case

It is alleged that in October 2017, the defendant rear-ended the plaintiff at an intersection in Dallas, Texas. The defendant, driving a Nissan Titan pickup truck, felt a “soft bump” during the collision, while the plaintiff, driving a Chevrolet Camaro, initially indicated she was not injured and did not feel any pain. However, upon returning home, the plaintiff noticed pain in her neck and back. Two weeks later, she visited the hospital, where X-rays showed spondylosis and degeneration but no fractures.

Reportedly, in January 2018, the plaintiff saw an orthopedic surgeon who suggested her injuries were caused or worsened by the accident. She was referred to a double board-certified doctor in anesthesiology and pain management. An MRI revealed cervical radiculopathy with cervical disk herniation. In March 2019, the plaintiff filed a negligence suit against the defendant, alleging his conduct was the proximate cause of her injuries. The parties entered into a Rule 11 Agreement in which the defendant stipulated to causing the accident, leading to a jury trial on the causation of the plaintiff’s injuries and damages.

Allegedly, at trial, the plaintiff’s experts provided testimony on her medical condition and future medical needs. The defendant’s expert, a biomechanical engineer and accident reconstructionist, testified about the impact forces during the collision but was unable to determine the speed of the vehicles or the cause of the plaintiff’s injuries with medical probability. As such, his testimony was subsequently excluded. The jury found in favor of the plaintiff and the defendant appealed.

Exclusion of Expert Testimony in Car Accident Cases

On appeal, the court reviewed whether the trial court abused its discretion by excluding the biomechanical engineer’s testimony about the severity of the accident’s impact. The trial court found the biomechanical engineer’s testimony irrelevant to the jury’s determination of causation and damages, as he could not link the forces generated by the collision to the plaintiff’s injuries. The court upheld this decision, emphasizing that expert testimony must be relevant and assist the jury in resolving factual disputes. They noted that while biomechanical engineers can often provide useful insights into accident forces and potential injuries, in the subject case, the biomechanical engineer’s testimony lacked a necessary connection between the accident forces and the plaintiff’s specific injuries.

The court explained that under Texas law, expert testimony must be both relevant and reliable to be admissible. The biomechanical engineer’s inability to provide a medical causation opinion meant his testimony did not meet these standards. Additionally, the court highlighted that previous cases had allowed biomechanical expert testimony only when it was directly tied to the injuries in question. Without such a connection, the biomechanical engineer’s testimony was not considered helpful to the jury.

Meet with a Trusted Texas Car Accident Attorney

If you were hurt in a car crash brought about by another person’s reckless driving, you may be able to recover compensation, and you should meet with an attorney to discuss what evidence you must provide to establish liability. Earl Drott is a trusted Texas car accident attorney with ample experience demonstrating fault in collision lawsuits, and if you hire him, he will work tirelessly on your behalf. You can contact Mr. Drott to arrange a free conference through the online form or by calling 903-531-9300.

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