Expert testimony is crucial in personal injury trials, helping juries understand an incident’s technical or scientific aspects. However, when experts testify outside the boundaries of their expertise, their opinions risk prejudicing the jury and affecting the case outcome. A recent decision from Florida’s Fifth District Court of Appeal highlights these issues, focusing on the scope of biomechanical expert testimony in personal injury cases. In this case, the appellate court ruled that the trial court improperly allowed a biomechanical engineer to offer medical causation opinions, exceeding the expert’s qualifications and warranting a new trial.
Biomechanical engineers are frequently called upon in personal injury cases to explain the forces involved in an accident and how a hypothetical person might respond to those forces. While their expertise is valuable in understanding mechanics and dynamics, it does not extend to diagnosing or determining the specific cause of an individual’s injuries. The Fifth District’s opinion underscores the importance of maintaining clear boundaries between engineering analysis and medical conclusions in personal injury litigation.
What Biomechanical Experts Can Address
Biomechanical engineers provide insight into how physical forces from an accident interact with the human body. Their analyses often focus on whether the forces involved could generate specific injury mechanisms in a general sense. For example, a biomechanical expert might testify about the likelihood of a particular type of injury occurring given the speed of a collision, the position of a vehicle occupant, or the physical properties of the human body. This type of testimony helps jurors understand the mechanics of the accident without delving into individualized medical conclusions.
The Fifth District Court reaffirmed that biomechanical experts are not qualified to provide opinions about the specific cause of an injury for an individual involved in an accident. Such determinations require medical training and expertise, including evaluating preexisting conditions, biological variability, and individual tolerance levels to physical forces. By distinguishing between permissible engineering opinions and impermissible medical causation testimony, the court emphasized the need to prevent jurors from being misled by overreaching expert conclusions.
Improper Testimony in the Recent Case
At the center of this case, a biomechanical engineer testified about whether the forces generated by the accident in question were sufficient to cause a specific cervical spine injury for an individual of a particular height and weight. Despite assurances from the defense that the expert would not offer medical opinions, the testimony ventured into medical causation. The expert opined that the accident could not have produced the injury alleged by the victim, directly addressing the precise cause of the victim’’s medical condition.
The appellate court found this testimony improper, explaining that biomechanical engineers lack the qualifications to render medical opinions. While the expert could discuss the forces involved in the collision and the general types of injuries those forces might cause, they could not opine on whether the specific accident caused the victim’s injuries. This testimony exceeded the permissible scope of biomechanical expertise and should have been excluded.
Impact on the Jury’s Verdict
The court also analyzed whether the improper testimony influenced the jury’s decision. Expert testimony often carries significant weight, particularly in cases where technical or scientific explanations are central to determining liability or damages. In this instance, the biomechanical expert’s testimony directly addressed the victim’s claim of permanent injury, asserting that the forces involved could not have caused the specific cervical spine injury at issue. Given the importance of this testimony to the defense’s argument, the court determined there was a reasonable possibility that it contributed to the verdict.
Because the jury ultimately found that the victim did not suffer a permanent injury, the appellate court concluded that the improper testimony likely influenced the outcome. The court reversed the trial court’s decision and remanded the case for a new trial, reinforcing the principle that expert testimony must remain within the boundaries of the witness’s qualifications.
Preserving the Integrity of Expert Testimony
This case highlights the critical role of trial courts in evaluating and managing expert testimony. Judges must ensure that experts testify only within their expertise, particularly when their opinions could significantly impact the jury’s understanding of the evidence. Allowing testimony that exceeds an expert’s qualifications risks unfairly swaying the jury and undermines the integrity of the judicial process.
For attorneys, this decision serves as a reminder to carefully vet expert witnesses and prepare for challenges to their testimony. When presenting an expert, it is essential to clearly define the scope of their opinions and avoid straying into medical causation. Opposing counsel should remain vigilant in objecting to testimony that exceeds the expert’s qualifications, as doing so preserves the fairness of the trial and protects their client’s rights.
Speak with an Experienced Miami Personal Injury Lawyer About Your Case Today
If you were recently injured in a preventable accident, it’s important you understand your rights. The Miami personal injury lawyers at Friedman Rodman Frank & Estrada have decades of experience helping clients from across South Florida pursue the compensation they need and deserve to get their lives back on track after a serious accident. We can help you hold the parties responsible for your injuries financially accountable, so you don’t have to worry about paying for another’s negligence. To learn more, and to schedule a free consultation today, call Friedman Rodman Frank & Estrada at 877-448-8585