Admissibility of Evidence Relating To Other Accidents in a UIM Claim

In Maryland, after you are involved in a car accident with an underinsured driver, you can file an underinsured motorist (UIM) claim with your insurance company. In such a case, you must promptly notify your insurer and provide evidence of the other driver’s negligence and damages. To secure compensation, you must also prove the extent of your injury and its connection to the accident.

In an underinsured motorist claim, things can get tricky if you have pre-existing injuries. In UIM claims involving pre-existing injuries, defendants are allowed to introduce evidence of other accidents and injuries to challenge the plaintiff’s claims regarding causation and damages. But how do courts evaluate the admissibility of evidence relating to pre-existing injuries in Maryland UIM claims? Read on!

Rules on Admitting Evidence in Maryland Car Accident Claims

In Maryland, evidence is generally admissible if it is relevant to an important issue in the case. However, the court must also consider whether the probative value (the likelihood of evidence to help prove something important in the case) of the evidence is significantly overshadowed by the risk of confusion, unfair bias, or misleading the jury. If the probative value of evidence is substantially outweighed by the danger of unfair prejudice, confusion, or misleading the jury, it may be considered inadmissible.

The above rule applies even in UIM cases and to evidence relating to pre-existing injuries in these claims. If the probative value of evidence relating to pre-existing injuries in a UIM claim is significantly outweighed by the risk of unfair bias, confusion, or misleading the jury, the evidence may not be allowed in court. However, if the opposite is true, the evidence will likely be admitted, allowing the jury to consider it when deciding whether the claimant’s injuries were truly caused by the accident at issue.

The Trautwein Case

In the case of Trautwein v. Erie Insurance Exchange, the plaintiff (Trautwein) sought underinsured motorist benefits from Erie Insurance after a car accident in 2011. He claimed the accident resulted in severe injuries, especially in his back and neck. However, the insurance company wanted to present evidence that showed Trautwein had been in other accidents (both before and after the 2011 accident) that also hurt his neck and back.

During trial, the claimant argued that this evidence should be excluded because it could unfairly prejudice the jury and distract from the main issue. The trial court disagreed and allowed Erie Insurance to present the evidence, deciding it was relevant to the question of causation and the extent of the plaintiff’s injuries.

Trautwein appealed that decision, but the Maryland Court of Special Appeals affirmed it. The court found that the evidence was admissible because the plaintiff claimed ongoing injuries to body parts that had been affected by other incidents. Additionally, the court noted that any potential for unfair prejudice was minimized by the trial court’s jury instructions, which clarified that the evidence should only be considered for limited purposes like determining causation and damages.

Understanding how courts handle evidence of other accidents can make or break a UIM case. The above decision is an important reminder that claimants need to carefully evaluate their injury history and prepare to argue both the relevance and fairness of introducing certain pieces of evidence at trial.

Contact Us for Legal Help

Contact our skilled Towson car accident lawyer at Hardball Law for help with a car accident claim in Towson, Baltimore, and throughout Maryland.

Source:

mdcourts.gov/sites/default/files/unreported-opinions/2244s17.pdf