Starlett King and Jeff Shetterly v. Brian Harrington
Docket: 05-1977
Court: Court of Appeals for the Seventh Circuit; May 9, 2006; Federal Appellate Court
Starlett King and Jeff Shetterly sued Brian Harrington for injuries from an automobile accident, invoking diversity jurisdiction due to claimed damages exceeding $75,000. The case was tried in the U.S. District Court for the Southern District of Indiana, resulting in a jury verdict favoring Harrington. The district court subsequently denied the plaintiffs' motion for a new trial, prompting their appeal.
The accident occurred on January 8, 2002, at the intersection of North Pine Street and Michigan Avenue in Indianapolis. King and Shetterly, traveling in one vehicle, alleged that Harrington acted negligently. Before trial, Harrington successfully moved to prevent any mention of his liability insurance. During the trial, the Indiana Officers' Standard Crash Report was submitted with redactions on the officer’s opinion regarding the accident cause and Harrington's insurance. Harrington testified that he entered the intersection on a yellow light and did not see the plaintiffs’ vehicle before the collision, while King claimed she had a green light when struck. Witness Lea Elaine Vermillion confirmed that the light was green for the plaintiffs.
The jury ruled in favor of Harrington, finding no negligence on his part. The plaintiffs' appeal contends that the court erred by excluding evidence of Harrington's insurance, redacting the crash report, admitting photographs of Harrington's vehicle damage, and denying the new trial motion. The appeal is reviewed under the Federal Rules of Evidence, with district court decisions on evidence admissibility examined for abuse of discretion, which is defined by specific criteria.
The trial court's decision to exclude evidence of liability insurance under Federal Rule of Evidence 411 was upheld because the plaintiffs, King and Shetterly, failed to demonstrate an alternative purpose for introducing the insurance evidence, which was relevant solely to the issue of negligence. Harrington sought a limiting instruction, and the court granted his motion without opposition from the plaintiffs. During appellate arguments, the plaintiffs did not provide a valid reason for admissibility.
Regarding Officer Carl Cress's testimony, the court restricted his ability to refresh his memory with the Crash Report, offer opinions on the accident's cause, and included redactions to the Report, specifically excluding details about Harrington's liability insurance. These redactions were mutually agreed upon before trial, and the plaintiffs could not contest them afterward. Cress was allowed to review the redacted Report during testimony but maintained he had no independent recollection of the accident. The court properly limited his testimony in accordance with the Federal Rules of Evidence, asserting that he had nothing to add beyond what was in the Report.
Additionally, the plaintiffs contested the admission of photographs depicting damage to Harrington's vehicle but cannot appeal this issue as they did not object at trial. Federal Rule of Evidence 103(a)(1) requires that a timely objection must be made for an appeal to be valid. Since defense counsel presented the photographs without objection from the plaintiffs, this claim cannot be reviewed on appeal.
Appellants seek reversal of the district court's denial of their motion for a new trial, contending that the jury's verdict was against the manifest weight of the evidence. A new trial is warranted only if it can be shown that no rational jury could have reached the verdict. King and Shetterly must demonstrate this by evaluating the evidence favorably for Harrington, with the jury's credibility determinations and evidence weight left intact. Under the Indiana Comparative Fault Act, the jury found Harrington not negligent, which precluded recovery for the plaintiffs. Appellants argue that the verdict lacked evidentiary support, relying on rejected arguments and testimony claiming the traffic light was green for them when they entered the intersection. However, counter-evidence indicated Harrington faced a yellow light, and damage to his vehicle was primarily on the rear, passenger side, suggesting his vehicle was struck from behind. Additionally, Vermillion's view of the appellants' vehicle was obstructed. Considering these factors and viewing the evidence in favor of Harrington, the court concludes that the jury had a reasonable basis to rule in his favor regarding negligence. Consequently, the jury's verdict is affirmed, and the motion for a new trial is denied.
