The plaintiff in a personal injury action arising from a motor vehicle accident brought a preliminary motion to exclude photographs of vehicle damage at trial.
The plaintiff argued the photographs were irrelevant since liability was admitted, and that admitting them without expert biomechanical evidence would invite unguided speculation by the jury that minor vehicle damage equates to minor injury.
The court dismissed the motion, holding that the photographs were relevant to causation and admissible without expert evidence, as causation is a matter of common sense.
The court noted that a jury instruction would be given to clarify that serious injuries can still result from low-impact collisions.
