Recently, a state appellate court issued a written opinion in a Texas truck accident case requiring the court to determine if the lower court properly excluded evidence of the plaintiff’s mental health diagnoses. Ultimately, the court concluded that such evidence was relevant and that the probative value of the evidence outweighed any potential prejudice caused by the admission of the evidence. Thus, the court reversed the jury’s verdict.
The Facts of the Case
According to the court’s recitation of the facts, a pedestrian was killed after she was run over by a semi-truck that was in the process of making a turn. Evidently, the truck was negotiating a tight corner that was complicated by the presence of another motorist on the road. As the truck driver made the turn, the side of the truck clipped the pedestrian, knocking her to the ground. The truck’s rear tires then ran over the pedestrian, killing her instantly.
The pedestrian’s family members filed a Texas wrongful death lawsuit against the driver and his employer. As a part of their defense, the defendants intended on introducing evidence that the pedestrian suffered from bipolar disorder and schizophrenia and had alcohol, cocaine, and oxycodone in her blood at the time of her death. The plaintiffs objected to the admission of the evidence and the trial court precluded its admission, finding that it was relevant but that any probative value was outweighed by potential prejudice. The defendants appealed.
On appeal, the court began by noting that evidence that is relevant is not necessarily admissible because another rule of evidence may exclude it. In this case, the plaintiff claimed that the evidence, although relevant, was inadmissible under Texas Rule of Evidence 403 because its probative value [was] substantially outweighed by the danger of unfair prejudice.”
The court, however, found that the probative value of the evidence outweighed any risk of unfair prejudice it presented. The court homed in on the term “unfair,” explaining that not all prejudice will be considered in the analysis. Here, one of the main issues in the case, according to the court, was why the plaintiff walked into the road as the semi-truck was turning. Thus, the court held that any mental health issues or substances that were in the plaintiff’s body might have helped the jury make its determination. The court explained that any potential prejudice that may result by the admission of the evidence was not unfair, and not outweighed by the probative value the evidence presented.
Have You Been Injured in a Texas Truck Accident?
If you or a loved one has recently been injured in a Texas truck accident, contact the dedicated San Antonio personal injury lawyers at the law firm of Carabin Shaw. At Carabin Shaw, we have an extensive history representing Texas injury victims, and know what it takes to succeed on our clients’ behalves. To learn more, call 800-862-1260 to schedule a free consultation today.
The Legal Doctrine of Negligent Entrustment in Texas Car Accident Cases, Texas Injury Lawyers Blog, December 11, 2018
Proving Intoxication in Texas Personal Injury Cases, Texas Injury Lawyers Blog, December 11, 2018
Court Finds State Liable for Injuries Caused by Drop-off on Road’s Edge, Texas Injury Lawyers Blog, October 19, 2018