Louisiana Personal Injury Lawyer Blog
The recent decision in Anderson v. State from the Louisiana Court of Appeal, Third Circuit, highlights the complexities of assessing damages in personal injury cases, particularly when the plaintiff has pre-existing medical conditions. The court’s ruling underscores the principle that even if a plaintiff has prior health issues, a defendant can still be held liable for exacerbating those conditions due to their negligence. This blog post will analyze the critical aspects of the Anderson case and its implications for personal injury claims in Louisiana.
Laura Anderson was involved in a car accident with Marlys Sanders, an employee of the State of Louisiana. Both parties had conflicting accounts of how the accident occurred. A jury found both parties 50% at fault but awarded Anderson no damages, concluding she didn’t sustain any injuries from the accident. Anderson appealed this decision.
The medical evidence presented at trial showed that Anderson had several pre-existing conditions, including diabetes, high blood pressure, and prior injuries from previous car accidents. However, she argued that the accident worsened her existing conditions.
The Court of Appeal reviewed the medical testimony and concluded that Anderson’s pre-existing conditions were indeed exacerbated by the accident. The court references the testimonies of multiple physicians: Dr. Rainey, Dr. Wyble, Dr. Williams, and Dr. Romero. Dr. Rainey and Dr. Wyble explicitly stated that the accident worsened the plaintiff’s existing conditions. While Dr. Romero expressed skepticism about the necessity of certain surgical procedures, he did not directly refute the claim that the accident aggravated the plaintiff’s problems. The court also notes the defense counsel’s acknowledgment during closing arguments that the plaintiff likely experienced an aggravation from the accident.
Ultimately, the court concludes that the jury’s finding of no injuries was manifestly erroneous. It acknowledges that the jury might have correctly determined that the plaintiff suffered no new injuries due to the accident. However, based on the uncontroverted medical evidence and the defense’s admission, the court firmly establishes that the accident did exacerbate the plaintiff’s pre-existing conditions.
The court’s opinion highlights the importance of considering the aggravation of pre-existing conditions in personal injury cases, even when the plaintiff has a complex medical history. The court’s meticulous examination of the medical evidence and its reliance on the physicians’ testimonies underscore the significance of expert opinions in determining causation and the extent of injuries in such cases.
Additional Sources: LAURA M. ANDERSON VERSUS STATE OF LOUISIANA, ET AL.
Written by Berniard Law Firm
Other Berniard Law Firm Articles on Car Accidents: Driver Not Liable for Passenger’s Injury in Accident Beyond His Control and  Louisiana Appellate Court Rules That Damages Awarded to Car Accident Victim Are Not Excessive Amount