In the case of State Farm Mutual Automobile Insurance Company v. Woodgett, Woodgett was rear-ended by Storms. Woodgett was insured with State Farm. After he reached a settlement with Storms’ insurer, Woodgett pursued an underinsured motorist claim against State Farm. After the case went to trial, the jury found a verdict in favor of Woodgett and against State Farm. At trial, Woodgett moved to prevent State Farm from introducing any evidence that concerned a second motor vehicle accident that had occurred after the car accidents with Storms. Counsel for State Farm objected and said that Woodgett admitted that his pain increased after the second accident, that he did not tell his doctors about the second accident, and that the doctors testified that minor injuries can cause the headaches that Woodgett had experienced. The Court ruled that there was no medical evidence that directly linked the second accident to Woodgett’s injuries, so it granted his motion.
On appeal, the Indiana Court of Appeals looked to whether the trial court abused its discretion in excluding evidence of the second car accident. State Farm argued that evidence of the second accident was admissible to inform the jury of a possible cause of Woodgett’s headaches. Woodgett argued that State Farm had sought to assert a possible cause of his injuries without any evidence, medical or otherwise, establishing a casual connection in order to invite confusion and speculation by the jury. The Court held that it was possible that there was a correlation between the second accident and Woodgett’s injuries and it remanded the case back to trial court.
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