Elsie Boudreaux and her mother, Thelma Bizette, passed away due to a car accident in Addis, Louisiana. The surviving family members brought a lawsuit against the Louisiana State Department of Transportation and Development (DOTD). A jury found the accident to be 60% the fault of Boudreaux and 40% the fault of the DOTD.
The DOTD appealed the trial court’s ruling, alleging it erred in denying their motion to exclude evidence of how the department collected crash reports at the accident site. They claimed evidence on crash report procedures was irrelevant to how the accident occurred. They also claimed they were unduly prejudiced because the evidence misled the jury.
Evidence is deemed relevant if it speaks to the existence of facts necessary to the cause of action. La. C.E. art. 401. Relevant evidence may be excluded if its use prejudices the other party, confuses the issues, or misleads the jury. La. C.E. art. 404. The trial court is given broad discretion on the admittance of evidence, and the appellate court may only overrule cases of extreme prejudice of a party’s rights. The appellate court must first consider whether the trial court was wrong and, if so, whether the evidence substantially affected the ruling. Maddox v. Bailey, 146 So.3d 590, 594 (La. App. 1 Cir. 5/19/14).
The appellate court analyzed that evidence was relevant in this case when it relates to previous accidents at the same place, under similar conditions, and caused by similar dangers. Therefore, the evidence on crash reports was relevant to show the dangerous nature of the intersection. In addition, the evidence would show any knowledge the DOTD had of the danger and whether it failed to respond to that knowledge.
In fact, there was a glitch in the crash report system, which provided a factual basis for a lack of knowledge of danger on the part of the DOTD. Ironically, the evidence on the crash report system likely helped the DOTD avoid a higher percentage of fault. The appellate court, therefore, concluded the trial court did not abuse its discretion in finding the evidence fit for the jury. The relevance of the evidence was not outweighed by any prejudice to the defendant or confusion about the issues, and the jury was not misled.
The decision of the trial court to admit the evidence at trial was affirmed. This case demonstrates both how evidence in the record can be challenged and the aspects of human psychology in play during jury trials.
Additional Sources: CHAUVIN V. STATE
Written by Berniard Law Firm Blog Writer: Corrinne Yoder-Mulkey
Additional Berniard Law Firm Articles on Evidence: Evidence of Health Insurance Write-Offs Should Not Be Excluded at Trial