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Tennessee Court Upholds Exclusion of Evidence For Lack of Relevance

wooded roadWhile relevance may seem like a straightforward concept to grasp during a trial, it can often be surprisingly complex. Judges are tasked with the difficult directive of keeping a trial on task and on point, which includes excluding evidence that may not be relevant to the actual issues being decided. Often, parties may feel that negative evidence about the other party is relevant to their whole story and should be considered by the jury, or small details should be included so that the jury has the full picture, while a judge finds such evidence irrelevant, unnecessary, and maybe even prejudicial. As discussed below, a recent case out of the Tennessee Court of Appeals considers whether evidence of a driver’s error, ultimately irrelevant to any legal claims, was wrongfully excluded from trial.

In this auto accident case, K.H. was driving down a two-lane road when J.G. approached from the opposite direction and made a left turn in front of K.H.’s vehicle and into a gas station. As a result, K.H.’s vehicle ran into the back of J.G.’s vehicle, causing damages. K.H. sued J.G. K.H. argued that J.G. was at fault for the accident because he failed to yield to her vehicle when turning, and multiple statutory violations occurred under Georgia law, including a failure to yield, a failure to ensure that a turn could be made, and a failure to exercise due care to avoid a collision. At trial, K.H. called the officer who had arrived on the scene to testify. He testified that he had arrived after the accident occurred and could not remember the details of the accident, but he read from the notes that he had prepared at the time. However, based on where the accident occurred, the officer stated that there was a double yellow line as a median in the road, and a turn across a double yellow line was illegal. However, the officer did not cite J.G. for the violation.

J.G. immediately objected to this testimony on the grounds that the officer could not recollect exactly what had happened, was not an expert on accident reconstruction, and did not personally witness the accident. J.G. also objected to any testimony regarding the double yellow line because K.H. did not allege this violation in her complaint. The trial court ultimately allowed the officer to testify as to when he arrived at the scene and what was said to him, but it did not allow him to reconstruct the accident or opine on what might have happened before he arrived, including whether J.G. might have crossed a double yellow line. The jury ultimately found K.H. 75% liable and J.G. 25% liable. K.H. moved for a new trial on the grounds that she should have been allowed to present the officer’s testimony about J.G. crossing a double yellow line and that she was prejudiced by not being able to do so. The trial court denied the motion, and K.H. appealed.

On appeal, the Tennessee Court of Appeals noted that evidence at trial must be relevant to be admissible, and thus it must have a tendency to make important facts relevant to the determination of liability more or less probable. Here, the court noted that there was no statute or law in Georgia that made it illegal for a driver to make a left turn across a double yellow line.

While Georgia statutes prohibit crossing a divided highway or crossing into the left side of the highway except under very certain circumstances, the court held that neither of these applied. The road at issue was not a divided highway, and J.G. was not crossing into the left side of the highway improperly. He was exiting the highway to get to a gas station. Accordingly, the court of appeals concluded that whether J.G. was crossing a double yellow line was not actually relevant to a determination of whether he had done anything wrong or illegal. The court noted that the jury was still able to consider whether J.G. negligently turned left in front of K.H.’s vehicle or failed to yield in turning, but it had decided that J.G. was not more at fault than K.H. Accordingly, the Court of Appeals determined that the trial court did not abuse its discretion in excluding the evidence.

Determining which evidence is relevant to a trial is ultimately at the discretion of a judge. However, plaintiffs must be prepared to make persuasive and well-reasoned arguments regarding the relevance of the evidence they seek to admit in order to help the judge in their case understand the necessity of including it. Experienced Tennessee car accident attorney Eric Beasley can evaluate the claims in your case, identify the evidence most important to establishing those claims, and fight for the admission of that evidence at trial. For more information or to discuss the circumstances of your case, contact the Law Office of Eric Beasley today at 615-859-2223.

Related Blog Posts:

Tennessee Court Denies Sudden Emergency Defense in Car Accident Case, Tennessee Personal Injury Blog, January 11, 2017.

Sixth Circuit Overturns Harsh Pleading Standard in Auto Accident Case, Tennessee Personal Injury Blog, December 6, 2016.

The Necessity of Proving Causation in Tennessee Auto Accident Claims -Denton v. Taylor, Tennessee Personal Injury Blog, August 18, 2016