Hamlett v. Carroll Fulmer Logistics Corp.

176 F. Supp. 3d 1360, 2016 U.S. Dist. LEXIS 46687, 2016 WL 1381800
CourtDistrict Court, S.D. Georgia
DecidedApril 6, 2016
DocketCase No. CV415-001
StatusPublished
Cited by9 cases

This text of 176 F. Supp. 3d 1360 (Hamlett v. Carroll Fulmer Logistics Corp.) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hamlett v. Carroll Fulmer Logistics Corp., 176 F. Supp. 3d 1360, 2016 U.S. Dist. LEXIS 46687, 2016 WL 1381800 (S.D. Ga. 2016).

Opinion

ORDER

G. R. SMITH, UNITED STATES MAGISTRATE JUDGE

After he returned from his overseas military deployment in 2014, Sergeant First Class Leroy Hamlett crashed his motorcycle into a truck driven by George Swartz and owned by Swartz’s employer, Carroll Fulmer Logistics Corporation (CFLC).1 Doe. 1-1 at 3; doc. 55 at 4. Georgia State Patrol Trooper Robert L. Scott, Jr. examined the scene just after the accident and found Swartz at fault. The crash occurred on a' four-lane road in Richmond Hill, Georgia. Hamlett had the right-of-way but Swartz made a left turn from his oncoming lane, causing Hamlett to collide with his truck’s front end. See doc. 37-2 at 89 (official accident report diagram). Scott issued an O.C.G.A. § 40-6-73 (failure to yield) citation to Swartz, who paid the fine. Doc. 1-1 at 3; doc, 55' at 4; doc. 68 at 13. Hamlett and his wife (consortium claim) sued Swartz, CFLC, and CFLC’s insurer. Doc. 1-1.2 He seeks compensatory and pu[1363]*1363nitive damages, plus O.C.G.A. § 13-6-11 attorney fees and costs.3 Id.

The defendants move for summary judgment against plaintiffs punitive damage and attorney fee claims. Docs. 34, 35 & 40. They also move to exclude expert witness Jeffrey Alan Kidd’s testimony about his calculations and diagrams because he failed to produce them with his written report by the Court’s disclosure deadline. Doc. 38, Finally, they move to exclude from trial Scott’s testimony on these topics: whether Hamlett was a cause of the accident; the percentage of Swartz’s fault; whether Hamlett should have avoided Swartz’s tractor trailer; and Hamlett’s alleged speed at impact. Doc. 37. The summary judgment motions are before the district judge. The exclusion motions are reached here.

I. ANALYSIS

A. Kidd’s Testimony

Hamlett hired Kidd as an accident reconstruction expert who, unsurprisingly, lays all the blame on Swartz. Doc. 25 at 3. His report supplies only the sources he’d been provided to review, then states his conclusions: that Swartz’s failure to keep a proper lookout and yield while turning left (he turned into Hamlett’s path) “is the sole cause of this collision.” Id. His report was incomplete, defendants contend, when it was disclosed to them by the Court’s July 23, 2015 deadline.4 Doc. 38-1. They insist he should not be permitted to supplement it after that deadline, during his deposition. Rule 26, they remind, prohibits procrastination and sandbagging.5 Doc. 38-1.

[1364]*1364Hamlett counters that Kidd’s report was only technically deficient. He expresses surprise at the defendants’ objection. The parties, he explains, have worked harmoniously on this matter, conferring in early August 2015 to schedule Kidd’s deposition for September 3, 2015. Doc. 45 at 4. He says he fully complied with defendants’ Notice to Produce on that deposition, and on August-24, 2015 — the week before Kidd’s deposition — the defendant’s produced their accident reconstructionist’s (James Sloan’s) report. Id. at 4-5. Hamlett provided that report to Kidd, who thus was able to respond and be cross-examined about it in defendants’ lengthy deposition of him. Id.6 “Just as Mr. Kidd, Sloan produced his file at his deposition,” and “Mr. Sloan thoroughly critiqued Mr. Kidd’s opinions during his deposition.” Doc. 45 at 6.

Too, Hamlett reminds, defendants failed to object on untimeliness grounds, even during Kidd’s deposition. In fact, they waited until over a month after Hamlet deposed Sloan (on September 28, 2015) to complain. Doc. 45 at 5-6. Plaintiff represents that “[t]he parties appeared to be working together to efficiently manage expert discovery without this Court’s involvement. It is only four months later that [defendants raise any issue with Mr. Kidd’s report.” Id. at 6.

Hamlett makes some valid points. Some flexibility in the discovery process is tolerable, depending on the circumstances. And some objections can seem nit-pickish. Defendants, for that matter, concede that they did not object to Kidd’s report when they first received it. Doc. 61 at 1. But that’s because, they explain, they had no objections to Kidd’s report at that time. They object now only to new opinions that Kidd first presented in his deposition (filed at doc. 38-4).

So, they conclude, Kidd can testify that Swartz failed to yield while turning left, turned into Hamlett’s path, and — on that basis only — is the sole. cause of the collision. Doc. 61 at 1-2. But they object to and want to exclude the new opinions that Kidd supplied at his deposition, including testimony about Hamlett’s ability to perceive and react to avoid the accident. That, they insist, violates what Rule 26(a)(2)(B)(i) otherwise requires: a “com-[1365]*1365píete statement of all opinions the witness will express and the basis and reasons for them.... ” Id. (emphasis added); see also id. (expert reports must include “how” and “why” the expert reached a particular result, not merely the expert’s conclusory opinions).

The Court agrees. The defendant’s showing (doc. 61 at 3-7, 8-11) is unrebutted. Rule 26(a)(2) deters procrastination and sandbagging.7 Hamlett did both. It is unacceptable to make a party wait, and thus be surprised, at a deposition. Hamlett provides no satisfactory explanation for missing the deadline here, and the defendants were prejudiced because they were denied, prior to the deposition, the full opportunity to digest Kidd’s information and formulate their deposition questions based on the same. To permit procrastinators to point to deposition questions as proof of no prejudice is to neuter the rule and deny adversaries the full benefit of pre-deposition, question-preparation time, if not the option to obviate a deposition expense outright. See supra n. 7. Hence, Kidd will not be permitted to testify on the distance traveled by either vehicle, the time it took for both to impact, or Hamlett’s ability to perceive and react to Swartz’s truck.8 Defendants’ exclusion motion is thus GRANTED.9

[1366]*1366B. Scott’s Testimony

To reiterate, Trooper Scott investigated the accident, ticketed Swartz, and opined that Swartz is 100% at fault. Doc. 37-1 at 2, 4 (citing doc. 37-2 at 45-46). Defendants move to exclude only some of his opinions — those they insist fail the admissibility standard established by Fed. R. Evid. 702 and Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993).10 Doc. 37-1 at 2. They “do not seek to exclude or limit Scott’s testimony regarding his accident scene observations, investigation results, or other, non-speculative, fact-based testimony.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
176 F. Supp. 3d 1360, 2016 U.S. Dist. LEXIS 46687, 2016 WL 1381800, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamlett-v-carroll-fulmer-logistics-corp-gasd-2016.