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Keywords

plaintiffdefendanttrialtestimonymotionsummary judgmentexpert witnesssustainedmotion for summary judgmentwitness testimony
plaintiffdefendantnegligencetestimonymotionsummary judgmentexpert witnessmotion for summary judgment

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Huddleston v. United States, Not Reported in Fed. Supp., 2019 WL 6879741

Facts

The Plaintiff claims to have sustained neck and back injuries from a vehicle accident. The Defendant argued that the Plaintiff could not establish causation due to the lack of expert witness testimony. The court noted that while the injuries were not readily observable, the Plaintiff's treating physician lay witnesses might still provide necessary testimony regarding causation.

While the parties’ briefing does not make the precise nature of Plaintiff's injuries clear, the Court's understanding from a review of the record is that Plaintiff is claiming neck and back injuries and not a type of injury that is readily observable such as a broken leg.

Issue

Whether the Plaintiff can establish medical causation for his injuries without expert witness testimony.

Defendant contends that summary judgment is appropriate because, given prior rulings of the Court, Plaintiff has no expert witness to testify that the vehicle accident at issue caused his injuries, and thus he cannot establish causation, a necessary element of his negligence claim.

Rule

Summary judgment is appropriate when there is no genuine dispute as to any material fact, and the burden shifts to the non-moving party to show that there is a genuine issue for trial. A lay witness may testify about causation if it was necessary for treatment decisions.

Summary judgment is appropriate where “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a).

Analysis

The court analyzed the Defendant's argument that the Plaintiff lacked admissible medical testimony to establish causation. It concluded that the Defendant had not demonstrated that none of the Plaintiff's treating physician lay witnesses could provide necessary testimony regarding causation. Therefore, the court found that the issue of medical causation remained a genuine issue for trial.

Here, even if Plaintiff has no witness to testify as an expert, Defendant has not shown that none of Plaintiff's treating physician lay witnesses needed to know the cause of the accident to treat Plaintiff or to make decisions about his treatment. Therefore, Defendant has not shown that Plaintiff has no admissible medical testimony to establish medical causation.

Conclusion

The court denied the Defendant's motion for summary judgment, allowing the case to proceed to trial.

Based on the foregoing, it is ORDERED AND ADJUDGED that Defendant's Motion for Summary Judgment [DE 52] is DENIED.

Who won?

The Plaintiff prevailed in this motion for summary judgment because the court found that there were genuine issues of material fact regarding medical causation that needed to be resolved at trial.

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