Charisse Robinson v. Chancler Prescott and Graybar Electric Company, Inc.

Summary

The United States District Court for the Eastern District of Tennessee ruled on Defendants’ motions in limine in a motor-vehicle-accident case. The court denied the motion insofar as it sought to preclude Plaintiff from testifying about missed workdays, lost wages, and the cause of certain immediately occurring pain, but granted the motion to exclude testimony about the value of medical bills absent expert proof of their reasonableness and necessity.

Holdings

1. Plaintiff may testify about her missed workdays and lost wages because her testimony may provide competent proof of those losses and whether her injuries caused an inability to work depends on the evidence presented at trial.
2. Plaintiff may testify about the pain she experienced immediately following the vehicle accident and continuing for a limited period afterward, including testimony that may establish causation of her head, neck, shoulder, and back pain.
3. Plaintiff is precluded from testifying about the value of her medical bills because she cannot recover medical-bill damages without expert proof establishing the reasonableness and necessity of the medical services and charges.

Questions Presented

1. Whether Plaintiff could testify about missed workdays and lost wages without additional expert proof connecting the claimed injuries to her inability to work.
2. Whether Plaintiff could testify as a lay witness about the cause of her head, neck, shoulder, and back pain immediately following the vehicle accident and continuing for a limited period.
3. Whether Plaintiff could testify about the value of her medical bills when she lacked expert proof establishing their reasonableness and necessity.

Disposition

other