Causation is a key element of any personal injury claim. What do we mean by that? Basically, if you are in a car accident and later sue the other driver for damages, it is not enough to show that person’s negligence led to the accident. You also need to show that the accident was the “proximate cause” of any physical, mental, or monetary loss that you suffered. Absent such proof causation, there is no viable personal injury claim.
Coleman v. State Farm Mutual Automobile Insurance Company
As a general rule, you do not need expert evidence, such as testimony from your doctor, to prove causation. As with every rule, there are exceptions. For instance, if your personal injury claim involves a “medical question” that requires specialized medical knowledge–i.e., something the average juror could not understand without some sort of guidance from a trained professional in that specialty–then the court will require such evidence before allowing a case to proceed.
A recent decision from a federal magistrate judge in Albany, Coleman v. State Farm Automobile Insurance Company, provides a helpful illustration of this point. This personal injury case addresses an October 2018 car accident. The plaintiff and the defendant were both driving their vehicles near the intersection of State Route 250 and Fussell Road. According to the plaintiff, the defendant failed to yield the right of way and collided with his vehicle.
The plaintiff’s lawsuit alleges damages based on injuries to his wrist, which required surgery after the accident. The defendant moved for partial summary judgment–a ruling without the need for a jury trial–on the question of causation. Specifically, the defense insisted that there was no proof the accident was the proximate cause of the plaintiff’s wrist injury. In support of this motion, the defense pointed to deposition testimony taken by one of the plaintiff’s doctors, who said he previously treated the plaintiff for an injury in that same wrist, which predated the accident. A defense expert who reviewed the plaintiff’s medical records similarly concluded that the plaintiff likely had a “history of trauma” that explained his wrist pain independent of the accident. From this, the defense inferred that this pre-existing condition, not the accident, is what necessitated the new surgery.
As the magistrate explained, the plaintiff produced sufficient evidence to “require presentation to a jury” on the causation issue. This evidence largely consists of statements from the plaintiff and his family that he had no history of wrist pain prior to the accident. While the plaintiff did not present any expert testimony of his own, he argued that a jury should still assess the validity of the defense’s expert testimony. The magistrate agreed. Ultimately, the magistrate noted, the jury could find that the plaintiff had failed to establish causation and that his wrist injury was the result of a pre-existing condition.