Earlier this month, an Indiana appellate court issued a written opinion in a personal injury case involving allegations that the plaintiff was seriously injured when he was involved in an accident that was caused by the defendant, who was drunk at the time. The case presented the court with the opportunity to discuss when previous convictions for driving under the influence are admissible, and if such evidence is admissible, for which purpose the jury may consider it.
The Facts of the Case
The plaintiff was driving to work when the defendant’s vehicle inexplicably crossed over the center median and collided with the plaintiff’s vehicle head-on. Police arrived on the scene and conducted a blood-alcohol test on the defendant, which revealed he was legally intoxicated. The defendant was subsequently arrested, charged, and convicted for driving under the influence.
The plaintiff later filed a personal injury case against the defendant, seeking compensation for the injuries he sustained in the accident. During the trial, the plaintiff presented evidence of the defendant’s driving history, which contained two prior instances in which the defendant was cited for driving while under the influence of alcohol in 1996 and 1983. The defendant objected to the introduction of this evidence, claiming that it was “more prejudicial than probative” and violated the rules of evidence. The court disagreed and admitted the evidence, and the jury awarded the plaintiff over $1,444,000 in compensatory damages and an additional $182,500 in punitive damages. The defendant appealed.
On Appeal, the Jury’s Verdict Is Affirmed
The appellate court held that the lower court came to the correct conclusion. Regarding the admissibility of the defendant’s previous DUI convictions, the court held that while they were not relevant to compensatory damages, they could be relevant to help establish punitive damages. Thus, since the plaintiff was seeking punitive damages in addition to compensatory damages, the admission of the prior DUI convictions was permissible for that limited purpose.
The court also held that, although the convictions were quite old, they still provided some value to the jury, and while the evidence was prejudicial, it was not unfairly so. The court explained that the evidence could be used to show that the defendant did not “learn his lesson” from the previous convictions. As a result of the court’s decision, the jury’s verdict in favor of the plaintiff was affirmed.
Have You Been Injured in an Indiana Car Accident?
If you or a loved one has recently been injured in any kind of Indiana car accident, you may be entitled to monetary compensation. The dedicated personal injury attorneys at the law firm of Parr Richey Frandsen Patterson Kruse have decades of experience handling a wide range of personal injury cases, including those arising from drunk driving accidents and other motor vehicle accidents. Call 888-532-7766 to schedule a free consultation with a dedicated attorney today. Calling is free and will not result in any obligation on your part unless we are able to help you obtain the compensation you deserve.
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Slip-and-Fall Accident in Fast Food Restaurant Results in Premises Liability Lawsuit, Indiana Injury Lawyer Blog, May 10, 2017
Court Dismisses Personal Injury Case, Applying “Firefighter’s Rule”, Indiana Injury Lawyer Blog, May 17, 2017