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Valedez v. Watkins Motor Lines – Zero Fault Verdict in Crash Case Reversed by Federal Appeals Court

Two commercial drivers were involved in a wreck on a highway exit ramp that resulted in serious and lasting injuries to one.
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A lawsuit was filed by the injured driver, and a jury returned a verdict finding zero fault by both parties. But that verdict was recently reversed by the U.S. Court of Appeals for the Eighth Circuit, after the panel determined the lower court had allowed improper admission of evidence at trial that likely had a substantial influence on the jury’s decision.

Broward County truck accident lawyers understand the primary dispute in Valedez v. Watkins Motor Lines, et al. was testimony derived from the investigating officer’s crash report, which was barred from the evidence prior to trial.

Typically in accident cases, crash reports are a crucial part of the body of evidence, as they represent the unbiased observations of a knowledgeable third party. However, there may be some instances where it is worthwhile for plaintiff attorneys to request a suppression of this evidence, where certain elements could be detrimental to the case. Still, there has to be a strong legal argument for suppression.

Here, the issue was the investigation officer who created the report was unavailable to testify about the conclusions he reached in the course of his analysis. The appellate court record doesn’t indicate why the officer was unavailable. However, all kinds of official reports or records can be deemed inadmissible if there is no one to substantiate their validity or explain the details. There are sometimes exceptions made, but the court must weigh these matters carefully.

In this situation, the court ruled that admission of the report would amount to hearsay. The court did allow that certain elements of the report could be introduced via the testimony of a sergeant for the police department, but the report could not be entered.

When trial got underway, the driver alleged to be at-fault testified the other driver, who was hauling a vehicle on a trailer, was completely stopped on the exit ramp, and that he never saw any brake lights as he approached.

Seeking to refute this assertion, the plaintiff attorney questioned the sergeant about whether there was any indication from the report that the defendant trucker mentioned right after the crash anything about the other driver being stopped. He had not. Additionally, the officer never checked a box indicating the injured driver was improperly stopped on the roadway.

Using this as a window to introduce further evidence from the report, the defense lawyer pressed further regarding the other boxes checked on the report. Specifically, under probable contributing causes, the officer indicated vehicle defects and improper lane or use change by the injured driver.

Although the report was never technically admitted to evidence, substantial portions of it containing the conclusions of the crash investigator were.

The appellate court determined this was a significant error. The court did not challenge the trial court’s decision to bar the report, as this was not an issue raised by the defense either during or after the trial. What the court held was that based on that ruling, the testimony given by the sergeant regarding the investigator’s findings was improper.

Therefore, the verdict was reversed and the case remanded.

Call Freeman Injury Law — 1-800-561-7777 for a free appointment to discuss your rights.

Additional Resources:
Valedez v. Watkins Motor Lines, et al., July 11, 2014, U.S. Court of Appeals for the Eighth Circuit

More Blog Entries:
Tracy Morgan Sues Walmart Over Truck Accident Injuries, July 10, 2014, Broward County Car Accident Lawyer Blog

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