Information of Subsequent Accident Admissible in Florida Car Wreck Case

In Maniglia v. Carpenter, two men were involved in a car wreck on a Florida highway. The accident allegedly took place when the left front part of one car hit the right rear part of another car while changing lanes. The parties disagreed about the severity of the accident. The defendant and his passenger asserted that the accident was minor, whereas the plaintiff claimed that the accident was severe.

On the day after the crash, the plaintiff went to a chiropractor for neck and back injuries. An x-ray revealed that there were no injuries except for normal “wear and tear,” with no indication of an acute injury. As a result, the chiropractor did not place any work restrictions on him.

Approximately one month later, the plaintiff crashed into a car while driving a golf cart. He was thrown from the cart and was then involved in a physical altercation with the police. Reports indicated that he was intoxicated when this incident took place.

The defendant had evidence that the plaintiff failed to mention this subsequent golf cart accident to his chiropractor before seeking a follow up exam. The defendant also presented evidence that the plaintiff sought treatment from a surgeon, who recommended that he have surgery based on some MRIs taken after the golf cart accident.

The defendant argued that evidence of the golf cart accident was relevant in two ways. Firstly, it could support the contention that the plaintiff’s injuries were not caused by the car accident, but instead by the subsequent golf cart accident and police altercation. Secondly, it could support the theory that the plaintiff was not a credible witness, and his testimony relating to the severity of the first wreck was not reliable.

The plaintiff filed a motion to exclude the evidence pertaining to the golf cart incident, reasoning it would be too prejudicial to his case. The trial court agreed, granted the plaintiff’s motion, and completely excluded evidence of the golf cart wreck.

The trial court awarded the plaintiff damages in excess of $180,000. The trial court denied the defendant’s motion for a new trial. The defendant appealed.

On appeal, the justices ruled that the trial court’s ruling was incorrect because the evidence of the golf cart accident was directly relevant to the issues of causation and credibility. Under Florida law, relevant evidence is inadmissible on the basis of prejudice only if the risk of unfair prejudice substantially outweighs its probative value. Here, the court noted that the probative nature of the information was not outweighed by the risk of unfair prejudice. Thus, the court reversed and remanded the case for a new trial.

If you’ve been injured in a Florida car accident, it is important to speak to a qualified attorney who can examine the facts of your case. At the Law Offices of Robert Dixon, our Miami car accident attorneys have represented clients in virtually all types of accident cases. We proudly represent clients across South Florida. To learn more, call us at 1-877-499-HURT (4878) or contact us online today.

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