Michael Accetta v. Doris Provencal; Michael Norato v. Doris Provencal

Summary

The Rhode Island Supreme Court reviewed a personal-injury action arising from a low-impact rear-end collision in which the defendant admitted liability but disputed causation and damages. The court held that photographs showing little or no vehicle damage were relevant and admissible without expert testimony, and it affirmed the denial of the plaintiffs' motion for a new trial. The court affirmed the Superior Court judgment.

Holdings

1. Photographs showing little or no visible damage to vehicles involved in a motor-vehicle collision are relevant to the force of the impact and the issue of whether the collision caused the plaintiffs' alleged injuries, and they are not inadmissible merely because plaintiffs offer no expert testimony concerning the relationship between property damage and bodily injury.
2. The Superior Court properly denied the plaintiffs' motion for a new trial because the trial justice conducted the required independent review of the evidence, assessed witness credibility, and articulated an adequate rationale for concluding that the jury acted reasonably.

Questions Presented

1. Whether the trial justice abused her discretion by admitting photographs of the vehicles involved in the collision, despite the absence of expert testimony concerning the relationship between vehicle damage and bodily injury.
2. Whether the trial justice abused her discretion by denying the plaintiffs' motion for a new trial on the grounds that the verdict was against the weight of the evidence and that admission of the photographs was erroneous.

Disposition

affirmed