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Tennessee Supreme Court Finds Jury Instruction On Superseding Cause Not Necessary

large truckIn many personal injury cases, the question of who caused an injury can be complicated. In a car accident, for example, there may be several actors at play who contributed to an accident, and the victim may have previously experienced back or neck pain. Or a personal injury victim may later suffer another accident or injury, making it difficult to determine how much of her pain was caused by the initial injury. In these types of situations, determining causation can become tricky, as the Tennessee Supreme Court noted in a recent case involving causation in a truck pileup.

This Tennessee truck accident case resulted from a three-truck pileup that occurred in Shelby County, Tennessee. D.B. was working as a truck driver and driving his truck in July 2009 when he came upon significant traffic. D.B. slowed down and was able to come to a complete stop. However, H.F., who was also driving a truck for his employer, Celadon, was not able to stop in time and ran into the back of D.B.’s truck. As D.B. was recovering from that impact, a third truck driven by S.D., on behalf of his employer, Chickasaw, ran into the back of H.F., causing further damage to H.F. and D.B.’s trucks.

Although he did not initially believe he was injured, D.B. later began to suffer back and neck pain that increased in severity over time. He was ultimately forced to file a workers’ compensation claim and seek medical treatment. His neurosurgeon at the time found that he was suffering from a disc herniation and put him on reduced work. Eventually, D.B. was forced to stop working altogether. In 2010, D.B. filed a lawsuit against Celadon and Chickasaw, alleging that the accident with their vehicles caused his injuries.

At trial, Celadon and Chickasaw introduced evidence that D.B. had been involved in a second car accident shortly after his truck accident, and they argued that this accident had at least partially, if not fully, caused D.B.’s injuries. After the trial was over, the judge instructed the jury as to causation under Tennessee law, including cause in fact and proximate cause, but denied Celadon’s request to instruct the jury on superseding events that could interrupt causation (like D.B.’s second accident). The trial court found there was not sufficient evidence of a superseding event to warrant the instruction. The jury ultimately awarded D.B. over three million dollars in damages.

Celadon appealed, and the Court of Appeals affirmed the lower court’s decision not to include the superseding instruction. Celadon then appealed again to the Tennessee Supreme Court, who agreed to hear the case.

The Tennessee Supreme Court first considered whether there was sufficient material evidence to justify the inclusion of the superseding event instruction. Unlike the two lower courts, the Supreme Court found that the evidence of D.B.’s second accident, the severity of the accident, and D.B.’s ongoing pain issues all constituted material evidence that would support a superseding event instruction. However, the Supreme Court then turned to consider whether the existing instructions provided by the court sufficiently addressed the causation issues, such that Celadon was not prejudiced by the error.

The Supreme Court found that the trial court had given all of the available Tennessee jury instructions on proximate cause and cause in fact, and it had adequately covered the issue for the jury so that they could consider whether the truck accident, or D.B.’s subsequent accident, caused his injuries. Since the instructions given fairly encompassed the claims and defenses at issue in the case, the Supreme Court concluded that Celadon was not prejudiced by the failure to include the superseding event instruction, and the trial court did not substantially err in failing to give the instruction.

Jury instructions can make a significant impact on any case, and making sure the necessary instructions are included to cover your claims, or defenses, is very important. As this case makes clear, however, instructions on superseding events do not necessarily need to be given when instructions adequately cover issues of causation as a whole. Knowledgeable Tennessee truck accident attorney Eric Beasley can help you address complicated issues of causation and craft jury instructions to address the unique circumstances of your case.  For more information or to discuss the circumstances of your case, contact the Law Office of Eric Beasley today at 615-859-2223.

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Tennessee Court Considers When a Party Can Be Held Liable For An Agent’s Negligence, Tennessee Personal Injury Blog, October 12, 2016