Pearce v. Estate of Day

Supreme Court of Alabama

Dale County | No. 1200623 | May 27, 2022

Court Upholds Verdict in Accident Case Linked to Driver's Medical Condition and Possible Impairment

In 2017, a vehicular accident involving an Enterprise driver, Day, led to multiple collisions, causing the deaths of Dewitt and Day. Day had prior health concerns, including heart issues, but had been cleared by his cardiologist to drive for Enterprise. On the accident day, Day's behavior was normal until he suddenly swerved into oncoming traffic. A post-mortem examination revealed Day had heart conditions, though the accident caused his death.

Enterprise sought to exclude evidence regarding Day's potential suicidal tendencies, a toxicology report indicating marijuana use, and other aspects of Day's medical history unrelated to the crash. The trial court granted these exclusions, focusing the trial on Enterprise's defense of sudden loss of consciousness. The jury ruled in favor of Day's estate and Enterprise. Pearce, representing Dewitt, appealed the decision, arguing that excluded evidence was crucial to refute the sudden loss of consciousness defense and the verdict was against the evidence's weight.

Pearce's appeal focused on the exclusion of evidence about Day's suicidal thoughts, extensive medical history, and marijuana use on the day of the accident. In response, Enterprise cited past cases where evidence regarding substance use was ruled irrelevant without proof of impairment at the time of an incident.

The court found no direct link between Day's medical conditions or substance use and the accident. They emphasized that knowledge of health risks doesn't equate to foreseeing a sudden loss of consciousness while driving. Upholding the jury's decision, the court concluded that substantial evidence suggested Day suffered a sudden heart attack causing the crash.

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