Elizabeth Goode v. Jaya Nair

2025 Ark. App. 414
CourtCourt of Appeals of Arkansas
DecidedSeptember 10, 2025
StatusPublished

This text of 2025 Ark. App. 414 (Elizabeth Goode v. Jaya Nair) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elizabeth Goode v. Jaya Nair, 2025 Ark. App. 414 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 414 ARKANSAS COURT OF APPEALS DIVISION IV No. CV-24-130

ELIZABETH GOODE Opinion Delivered September 10, 2025

APPELLANT APPEAL FROM THE PULASKI COUNTY CIRCUIT COURT, FOURTH V. DIVISION [NO. 60CV-17-608] JAYA NAIR APPELLEE HONORABLE HERBERT WRIGHT, JUDGE

AFFIRMED

ROBERT J. GLADWIN, Judge

Elizabeth Goode appeals from the September 19, 2023 final amended judgment

entered by the Pulaski County Circuit Court following a jury trial of a motor-vehicle-collision

claim involving injuries sustained by Goode. Goode argues that the circuit court committed

prejudicial abuses of discretion by excluding relevant evidence tending to discredit appellee

Jaya Nair’s medical expert and by imposing a twenty-minute time limit per juror panel during

voir dire. We affirm.

I. Facts and Procedural History

The case was tried to a Pulaski County jury on August 1–3, 2023. During the pretrial

conference immediately before voir dire, the circuit court informed the parties that each side

would have twenty minutes for voir dire for each of the two eighteen-member jury panels.

The circuit court allowed each side five peremptory strikes to be used between the two eighteen-member jury panels. Through a hand-delivered motion to the circuit court, Goode

requested more time to conduct voir dire and identified the following five areas of inquiry

as the basis for why more time was needed to conduct meaningful voir dire for this motor-

vehicle-collision case:

1. The individual beliefs of all venire people on the applicable burden of proof in civil cases (preponderance versus reasonable doubt);

2. The individual beliefs of all venire people on whether compensation should be allowed for the aggravation of a preexisting condition (some believe any pre- existing condition is disqualifying and admit they would follow their personal belief and not the jury instruction requiring otherwise);

3. The individual beliefs of all venire people on the amount of compensation that should be allowed (some are against jury verdicts for large amounts regardless of the facts and admit they would follow their personal belief and not the jury instructions requiring otherwise);

4. The individual beliefs of all venire people on the amount of compensation that should be allowed for the pain and suffering element of damage (some are against giving any money for pain and suffering because it is too speculative and admit they would follow their personal belief and not the jury instruction requiring otherwise); and

5. The individual beliefs of all venire people on the type of treatment Goode received (chiropractic physician versus medical doctor).

The circuit court considered the motion and stated it would follow the twenty-minute time

limit, but the court agreed to give counsel leeway if more time for important issues was

needed and requested.

After Goode’s counsel worked through several of these questions with the first panel,

Nair’s counsel made a twenty-minute time-limit objection. The circuit court imposed the

twenty-minute time limit for the first eighteen-member panel despite Goode’s request for

2 more time as per the circuit court’s previous order. As a result, Goode’s counsel was unable

to elicit any information from the first panel on the prospective jurors’ beliefs regarding the

type of treatment Goode received; specifically, whether the prospective jurors leaned one way

or the other regarding the weight they would give a chiropractic physician versus a medical

doctor. The second panel was questioned without incident related to the time limit, and two

individuals were struck for cause due to bias against chiropractic physicians.

Before trial, Nair conducted a video deposition of Dr. Wayne Bruffett, M.D., for use

at trial. Nair had retained Dr. Bruffett as a defense expert. During the deposition, Dr.

Bruffett testified that his medical-legal case documents were kept under the control of Zorian

Pride, his department manager. Dr. Bruffett agreed that after the deposition concluded, he

would have Ms. Pride provide certain requested documents that would be given to the court

reporter to attach as exhibits to his deposition. Specifically, Dr. Bruffett agreed to have Ms.

Pride produce his engagement letter with Nair’s defense law firm that hired him to be

attached as exhibit 5 to his deposition, which was completed as shown by the deposition

exhibit list.

Dr. Bruffett agreed that the financial information, including his payment under the

defense-law firm engagement letter (exhibit 5), would be provided by Ms. Pride and attached

as exhibit 6 to the deposition, showing how much the defense paid him in the case for his

medical-legal examination and report as well as how much he was paid to testify at the

deposition. A record showing payment of $6,000 to Dr. Bruffett’s clinic was provided and

3 attached as exhibit 6 to the deposition; however, Dr. Bruffett did not attach documents

showing how much he was paid for his deposition testimony.

Dr. Bruffett was also asked to provide—and attach as exhibit 8 to his deposition—the

billing and revenue generation from providing medical-legal defense examinations of injury

patients for the previous four-year period. Dr. Bruffett failed to provide these documents to

attach as exhibit 8 as shown by the deposition exhibit list.

After Nair played the video deposition of Dr. Bruffett for the jury during her case-in-

chief, Goode sought to introduce the deposition exhibits 1 through 8 that were

authenticated and discussed by Dr. Bruffett during his deposition, with the expectation that

the exhibits would be published to the jury. The circuit court denied the introduction of the

set of exhibits, which prevented the jury from seeing exhibit 6 and learning that the defense

had paid Dr. Bruffett $6,000 for a ten-minute medical exam, records review, and report

writing. The circuit court’s denial occurred after a series of proffers was made related to issues

involving the subpoenaed office manager rebuttal witness, Ms. Pride, being excluded by the

circuit court during a hearing held while the jury was taking a break. These proffered exhibits,

shown on the exhibit list attached to Dr. Bruffett’s deposition, included the following:

Exhibit 1: Subpoena served on Dr. Bruffett July 20, 2021, a year before his deposition.

Exhibit 2: Affidavit by Dr. Bruffett in response to the served subpoena stating he had no documents responsive to the request for copies of records related to his medical- legal case work for the previous four years, including list of cases referred to him and by whom, 1099 forms showing payments received, and referrals received from the defense law firm in this case. Dr. Bruffett’s affidavit was contradicted by his deposition testimony that his department manager, Zorian Pride, had possession of these business records involving his past medical-legal case work.

4 Exhibit 3: Clinic forms completed and submitted by Goode before being examined by Dr. Bruffett.

Exhibit 4: Lists provided by Goode to Dr. Bruffett during her ten-minute defense medical exam, describing how her life changed after the collision to include things that she can still do but which cause pain and problems later, things she rarely does, and things she can still do but with difficulty or pain.

Exhibit 5: Engagement letter from Laser Law Firm to Dr. Bruffett dated January 3, 2019.

Exhibit 6: Partial payment ledger of payment made to Dr.

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2025 Ark. App. 414, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elizabeth-goode-v-jaya-nair-arkctapp-2025.