Destan Seferaj v. United States Postal Service

CourtDistrict Court, C.D. California
DecidedAugust 28, 2023
Docket2:21-cv-06928
StatusUnknown

This text of Destan Seferaj v. United States Postal Service (Destan Seferaj v. United States Postal Service) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Destan Seferaj v. United States Postal Service, (C.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 DESTAN SEFERAJ, ) Case No. CV 21-6928-DMG (AFMx) 11 ) Plaintiff, ) 12 ) FINDINGS OF FACT AND v. ) CONCLUSIONS OF LAW 13 ) ) 14 ) UNITED STATES OF AMERICA, ) 15 ) Defendant. ) 16 ) ) 17 ) ) 18 ) ) 19 ) 20 21 This matter is below the Court following a one-day bench trial on January 17, 2023. 22 William A. Percy and Benjamin Dischyan appeared on behalf of Plaintiff Destan Seferaj. 23 Gregory J. Agron and Daniel A. Beck appeared on behalf of the United States of America. 24 Having carefully reviewed the evidence and the arguments of counsel, as presented at trial 25 and in their written submissions, the Court issues the following findings of fact and 26 conclusions of law pursuant to Rule 52 of the Federal Rules of Civil Procedure. 27 28 1 I. 2 MOTION FOR JUDGMENT AS A MATTER OF LAW 3 At the close of trial, the Government moved for judgment as a matter of law, on the 4 basis that Seferaj failed to offer sufficient proof that the car accident at issue in this case 5 actually cased the injuries of which he complains. For the reasons set forth below, the 6 motion for judgment as a matter of law is DENIED. 7 A. Dr. Nayab’s Competence to Offer a Causation Opinion 8 Seferaj’s only evidence of causation was the testimony of his treating chiropractor, 9 Dr. Laila Nayab, who testified that the injuries to Seferaj’s back and neck were caused by 10 his accident. But the Government contends that Dr. Nayab, as a chiropractor, is not 11 qualified to offer a medical opinion. 12 Under California law, “[q]ualifications other than a license to practice medicine may 13 serve to qualify a witness to give a medical opinion.” People v. Catlin, 26 Cal. 4th 81, 131 14 (2001), as modified (Sept. 26, 2001). In Catlin, the California Supreme Court concluded 15 that a toxicologist with “advanced training” in “occupational medicine, physiology, and 16 pharmacology,” with extensive professional experience in the field of agricultural poison 17 toxicology, was qualified to testify that poisoning had caused a victim’s death. Id.; see 18 also id. (noting “general trend . . . toward liberalizing the rules relating to the testimonial 19 qualifications of medical experts”) (citations omitted); Hernandez v. Amcord, Inc., 215 Cal. 20 App. 4th 659, 675 (2013) (non-M.D. epidemiologist qualified to opine as to causation in 21 asbestos exposure case). Title 16 of the California Code of Regulations, which governs 22 the licensing of chiropractors in the state, authorizes licensed chiropractors to diagnose and 23 treat injuries, “in a manner consistent with chiropractic methods and techniques,” “so long 24 as such methods and treatment do not constitute the practice of medicine by exceeding the 25 legal scope of chiropractic practice as set forth in this section.” Cal. Code Regs. tit. 16, § 26 302(a)(3).1 27 1 The section prohibits chiropractors from, for example, delivering children and practicing surgery, 28 dentistry, or optometry. Id. at § 302(a)(4). 1 Neither party has identified a California case, or a federal case applying California 2 law, holding one way or the other as to the question of whether a chiropractor is qualified 3 to offer an opinion as to medical causation in California. Other states’ courts have 4 generally concluded, however, that a chiropractor was qualified to offer an opinion as to 5 medical causation in tort cases. See, e.g., Knapp v. Wilkins, 786 So. 2d 457, 463 (Ala. 6 2000), as modified on denial of reh'g (Nov. 22, 2000) (concluding under Alabama law that 7 a chiropractor licensed to diagnose patients could testify as to the cause of a patient’s 8 injuries); Shackelford v. Cortec, Inc., 8 Ohio App. 3d 418, 419 (1982) (chiropractor’s 9 opinion admissible to prove causation under Ohio law where chiropractors licensed to 10 “diagnose” patients); Whittaker v. Houston, 888 A.2d 219, 223 (Del. 2005) (same under 11 Delaware law); but see Totton v. Bukofchan, 80 N.E.3d 891, 894 (Ind. Ct. App. 2017) 12 (chiropractor not qualified to render opinion as to medical causation, but only because the 13 medical causation issue was particularly complex). Given California’s “trend toward 14 liberalizing the rules” regarding medical causation, Catlin, 26 Cal. 4th at 131, Dr. Nayab 15 will be permitted to offer an opinion as to medical causation under the circumstances of 16 this case. 17 B. Failure to Consider Other Potential Causes 18 The Government argues that Dr. Nayab failed to properly consider other potential 19 causes of Seferaj’s injuries, and instead relied only on his assertion that his pain was caused 20 by the accident. 21 “[I]n a personal injury action causation must be proven within a reasonable medical 22 probability based upon competent expert testimony.” Jones v. Ortho Pharm. Corp., 163 23 Cal. App. 3d 396, 402 (1985). “A possible cause only becomes ‘probable’ when, in the 24 absence of other reasonable causal explanations, it becomes more likely than not that the 25 injury was a result of its action.” Id. at 403. 26 [A]n expert's conclusory opinion that something did occur, when 27 unaccompanied by a reasoned explanation illuminating how the expert 28 employed his or her superior knowledge and training to connect the facts with 1 the ultimate conclusion, does not assist the jury. In this latter circumstance, 2 the jury remains unenlightened in how or why the facts could support the 3 conclusion urged by the expert, and therefore the jury remains unequipped 4 with the tools to decide whether it is more probable than not that the facts do 5 support the conclusion urged by the expert. 6 Jennings v. Palomar Pomerado Health Sys., Inc., 114 Cal. App. 4th 1108, 1117 (2003). 7 Dr. Nayab attested that Seferaj reported to her that the force of his accident “caused 8 his head to hit the headrest and his chest to hit the steering wheel,” and that he “twisted to 9 the left and back quickly out of fear that the airbag would deploy.” Nayab Decl. ¶ 3. 10 Seferaj told her that his symptoms began following the accident. Id. He did not report “a 11 significant medical history” for the affected body parts prior to the accident. Id. at ¶ 7. 12 Accordingly, Dr. Nayab concluded that the accident was the cause of his symptoms “to a 13 reasonable degree of medical probability.” Id. Dr. Nayab also reviewed x-rays and ordered 14 an MRI to confirm this diagnosis. See Trial Tr. at 61:12–17. 15 The Government argues that Dr. Nayab’s testimony is insufficient to establish the 16 requisite factual basis for her conclusion that Seferaj’s injury was caused by the accident. 17 Dr. Nayab testified that she never reviewed Seferaj’s medical records. See Trial Tr. at 57:1 18 –23. She also testified that she “would be surprised” to learn that Seferaj went to the 19 emergency room repeatedly while treating with her, but that he did not complain of any 20 neck or back pain at the emergency room. Id. at 60:23–61:2, 63:19–64:6. And she 21 acknowledged that the disc degeneration noted in her imaging could also have been caused 22 by wear and tear over time, including by lifting heavy objects. Id. at 70:3–71:6. 23 Although Dr. Nayab’s reasoning regarding causation is brief, the Court concludes 24 that it is sufficient to establish causation. Dr.

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Destan Seferaj v. United States Postal Service, Counsel Stack Legal Research, https://law.counselstack.com/opinion/destan-seferaj-v-united-states-postal-service-cacd-2023.