Schmidt v. Van

Summary

The Florida First District Court of Appeal reviewed an order granting the plaintiffs a new trial after a jury found that the defendant's automobile accident did not cause the plaintiff's injuries. The court held that the trial court improperly disregarded conflicting lay testimony and the jury's authority to reject expert testimony, reversed the new-trial order, and remanded for reinstatement of the jury verdict.

Holdings

1. The trial court abused its discretion in granting a new trial because its determination that the verdict was against the manifest weight of the evidence rested on the legally erroneous premise that the jury could not reject the medical experts' causation opinions.
2. A jury may accept or reject expert testimony, including medical causation testimony, when the evidence provides a reasonable basis for rejecting it; conflicting lay testimony or other evidence may supply that basis.

Questions Presented

1. Whether the trial court abused its discretion by granting a new trial on the ground that the jury's no-causation verdict was against the manifest weight of the evidence.
2. Whether a jury may reject expert medical testimony on causation when conflicting lay testimony and other evidence provide a reasonable basis for doing so.

Disposition

reversed_and_remanded