Third Circuit Affirms Denial of Post-Trial Motions in a Trucking Accident Case

In the case of Sweigart v. Voyager Trucking Corp., No. 23-2397 (3d Cir. July 29, 2024 Bumb, J., Jordan, J., and Smith, J.) (Op. by Bumb, C.J.), the Third Circuit affirmed a trial court decision denying post-trial motions in a trucking accident case that resulted in verdict for the Plaintiff in the amount of $25 million.

In this case, the court ruled that there was no abuse of discretion by the trial court in denying a bifurcation of the liability and damages issues.  The defense sought bifurcation given the serious nature of the Plaintiff's injuries and the fear that that evidence would "infect" the jury's decision on the liability issues.   The court noted that many personal injury case involved serious injuries. The Third Circuit also stated that to hold that a trial court abuses its discretion in denying bifurcation just because a case involves serious personal injuries would flip the presumption against bifurcation. Under the law, the jury is presumed to be able to follow jury instructions to compartmentalize the evidence.

The court also noted that the fact that a juror fainted at trial in response to the presentation of graphic injury evidence does not require a mistrial. The appellate court found that it was not an abuse of discretion by the trial court to deny a mistrial motion where the jury questioning confirmed that the juror could continue and remain impartial.

The appellate court also found that the fact that the Plaintiff’s treating physician rendered medical help to the juror that fainted also did not support a mistrial since the physician was only a witness and to an opposing party.

The court noted that, on appeal, a trial judge’s estimation of a prospective juror’s impartiality shall not be second guessed.

Turning to other issues, the appellate court held that the trial court properly balanced the sudden emergency doctrine with an instruction on the assured clear distance rule. The court agreed that it was for the jury to decide if a sudden emergency existed.

The appellate court also found that it was not an abuse of discretion to exclude evidence of the Plaintiff’s lack of a motorcycle license. The court noted that there was no causal connection between the accident and the Plaintiff’s lack of a motorcycle license. 

The court also found that it was not an abuse of discretion to exclude videos of reckless driving by the Plaintiff at other times. The court noted that prior bad acts cannot be admitted to show a propensity to act in the same way all the time. The evidence at issue in this case did not rise to the level of habit evidence.

Anyone wishing to review a copy of this decision may click this LINK.


I send thanks to Attorney James M. Beck of the Reed Smith law firm in Philadelphia for bringing this case to my attention.