Blinn v. Sindwani

Syllabus

The plaintiff sought to recover damages from the defendant for negligence in connection with personal injuries sustained by the plaintiff in an automobile accident that occurred in 2012. The plaintiff alleged, inter alia, that the accident caused him to suffer mental anguish and exacer- bated preexisting conditions of anxiety and depression, for which he sought treatment in 2014 and 2015. During trial, the parties had agreed to enter into evidence certain treatment records of a mental health treatment provider from whom the plaintiff sought counseling in 2104 and again in 2015 and 2016. The treatment records contained references to various incidents of the plaintiff's prior misconduct, including a prior conviction of operating a motor vehicle while under the influence of intoxicating liquor or drugs, and a citation he had received for his alleged involvement in a 2014 motor vehicle accident. The trial court sustained the defendant's objections to the plaintiff's motions in limine, which sought to exclude all references to his prior convictions and misconduct, as well as the citation. After the jury returned a verdict in favor of the plaintiff, the trial court rendered judgment in accordance with the ver- dict, from which the plaintiff appealed to this court. Held: 1. The plaintiff's claim that the evidence of his prior misconduct should have been precluded was unavailing; the prior misconduct evidence was relevant to the issue of whether the 2012 accident caused emotional distress for which the plaintiff claimed damages and sought treatment in 2014 and 2015, as it tended to show that the plaintiff's treatment at the mental health service provider did not result from the 2012 accident but, rather, resulted from other events and stressors in his life, including the prior misconduct, and the trial court properly determined that the probative value of the evidence outweighed its prejudicial effect and did not abuse its discretion in sustaining the defendant's objection