COA reverses judgment against State Farm, finds trial court erred in excluding evidence

The Indiana Court of Appeals reversed a judgment Tuesday against State Farm Mutual Automobile Insurance Co. after finding that a trial court erred in excluding evidence that could have proven the insurance company did not play a role in an accident that led to the plaintiff suffering from severe migraine headaches.

State Farm appealed in the case of State Farm Mutual Automobile Insurance Company v. Sean Woodgett, 18A02-1505-CT-292, after the Delaware Circuit Court entered judgment in favor of Sean Woodgett for $85,000 against State Farm and Timmie Storms, whose vehicle struck Woodgett’s van from behind in September 2011, forcing the van to roll into the back of another vehicle. Woodgett had uninsured/underinsured motorist coverage at the time of the accident.

Woodgett was taken to the hospital and treated for neck pain and headaches. After undergoing physical therapy, Woodgett reported in February 2012 that his headaches were slight and came infrequently, but later began visiting a neurologist in 2013 for very severe headaches three to four times a week. The neurologist, Dr. Wuff, eventually diagnosed Woodgett with migraines.

Woodgett filed for damages against Storms and State Farm in 2013 and moved in the 2015 trial that State Farm be precluded from presenting evidence related to another accident Woodgett was involved in during the fall of 2012.

Counsel for State Farm alleged that Woodgett’s increasing headaches, which he first reported in January 2013, were related to the second accident in 2012. But the Delaware Circuit Court ruled that there was no medical evidence that directly spoke to the issues of the injury Woodgett suffered after the second accident and, thus, granted Woodgett’s motion, prompting State Farm’s appeal after the court entered judgment in favor of Woodgett.

In its reversal, the Court of Appeals wrote that a logical nexus existed between the second accident and the subsequent migraine headaches. That nexus was sufficient enough to show that the second accident was the possible cause of the migraines and, thus, that the trial court abused its discretion in excluding evidence of the second accident, the Court of Appeals wrote.

Further, the court wrote that the trial court’s error was inconsistent with substantial justice.

“This exclusion went to the heart of the matter that the jury was asked to decide – the extent to which Woodgett’s accident with Storms caused the headaches experienced by Woodgett and, in particular, the severe migraine headaches,” the Court of Appeals wrote.

The Court of Appeals remanded the case for further proceedings.