John McGaughey v. Jenny Warnick

CourtCourt of Appeals of Kentucky
DecidedDecember 7, 2023
Docket2023 CA 000343
StatusUnknown

This text of John McGaughey v. Jenny Warnick (John McGaughey v. Jenny Warnick) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John McGaughey v. Jenny Warnick, (Ky. Ct. App. 2023).

Opinion

RENDERED: DECEMBER 8, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0343-MR

JOHN MCGAUGHEY APPELLANT

APPEAL FROM WOODFORD CIRCUIT COURT v. HONORABLE KATHRYN H. GABHART, JUDGE ACTION NO. 19-CI-00157

JENNY WARNICK APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; ECKERLE AND KAREM, JUDGES.

THOMPSON, CHIEF JUDGE: John McGaughey appeals from an order of the

Woodford Circuit Court which denied his motion for a new trial. Appellant argues

that he was entitled to a new trial due to attorney misconduct and because the trial

court erroneously allowed certain testimony into evidence. We find no error and

affirm. FACTS AND PROCEDURAL HISTORY

On June 30, 2018, Appellant and Jenny Warnick were involved in a

motor vehicle accident. At trial, Appellee claimed that while she was turning

around in someone’s driveway, she looked to her left and saw Appellant and his

motorcycle on the ground. Her theory at trial was that Appellant lost control of his

motorcycle while coming around a nearby curve, causing him to crash.

Appellant claimed that when he rounded the nearby curve, he saw

Appellee’s car in both lanes of the road. Appellant then claimed that he did not

have room to maneuver around the vehicle; therefore, he chose to “lay his

motorcycle down” to prevent a crash. Both parties agree that there was no

collision between the two vehicles.

The jury eventually returned a verdict finding both parties fifty

percent at fault. Appellant later filed a motion for a new trial alleging attorney

misconduct and the improper inclusion of evidence. The trial court denied the

motion and this appeal followed.

STANDARD OF REVIEW

Kentucky Rules of Civil Procedure (CR) 59.01 states:

A new trial may be granted to all or any of the parties and on all or part of the issues for any of the following causes:

(a) Irregularity in the proceedings of the court, jury or prevailing party, or an order of the court, or abuse of

-2- discretion, by which the party was prevented from having a fair trial.

(b) Misconduct of the jury, of the prevailing party, or of his attorney.

(c) Accident or surprise which ordinary prudence could not have guarded against.

(d) Excessive or inadequate damages, appearing to have been given under the influence of passion or prejudice or in disregard of the evidence or the instructions of the court.

(e) Error in the assessment of the amount of recovery whether too large or too small.

(f) That the verdict is not sustained by sufficient evidence, or is contrary to law.

(g) Newly discovered evidence, material for the party applying, which he could not, with reasonable diligence, have discovered and produced at the trial.

(h) Errors of law occurring at the trial and objected to by the party under the provisions of these rules.

We review a trial court’s determination that grounds for a new trial exist under the

clearly erroneous standard. If such grounds exist, we then review the decision

whether to grant a new trial for abuse of discretion. Gibson v. Fuel Transport,

Inc., 410 S.W.3d 56, 62 (Ky. 2013).

ANALYSIS

Appellant’s first argument on appeal is that Appellee’s attorney

referred to Appellant’s vehicle as unit one, which had been prohibited via a motion

-3- in limine. Prior to trial, Appellant moved to prohibit the introduction of the police

report created for this accident. Appellant also moved to preclude any mention

that Appellant was named as “unit 1” in the report and Appellee was listed as a

witness. Appellant believed that any reference to Appellant being named as “unit

one” and Appellee being listed as a witness would cause the jury to infer that

Appellant was the cause of the accident. In addition, Appellant believed that some

members of the jury who had been in an accident or were related to police officers

would know that a person named as “unit 1” in a police report would be considered

by the police as the cause of the accident. This motion was granted.

During Appellant’s cross-examination, trial counsel for Appellee,

Bradford Breeding, questioned Appellant about the accident and previous

statements he made to the officer who created the accident report. Mr. Breeding

began referencing Appellant’s statements made during a deposition. During the

deposition, Appellant was asked about the accident report and references were

made to him being “unit 1.” At trial, Mr. Breeding showed the deposition to

Appellant and, in order to orient him to the section to which he was referring,

stated that he was referring to the section where he was named as “unit 1.”

Counsel for Appellant objected at the mention of “unit 1” and a bench

conference was held. Mr. Breeding was reminded not to refer to “unit 1.” The

trial court also admonished the jury not to consider the last question asked by Mr.

-4- Breeding. Mr. Breeding then continued with Appellant’s cross-examination and

again asked about statements he might have made to a police officer. During the

course of answering the question, Appellant read a part of his prior deposition and

stated he was described as “unit 1.”

At this point another bench conference was held and Mr. Breeding

stated he would move on to a different line of questioning. After the bench

conference, the trial court gave another admonition to the jury. The court told the

jury to disregard the part of Appellant’s testimony where he read from his

deposition and stated that any “reference to the term unit one carries no weight in

this trial.”

Appellant claims on appeal that when defense counsel used the term

unit one and the elicited testimony where the term was used again, counsel was

committing misconduct. Appellant claims that the term should not have been used

at trial due to the motion in limine and that counsel purposefully caused it to be

said in front of the jury. Appellant believes that this caused the jury to infer that

Appellant was the cause of the accident.

We believe the use of the term “unit 1” on two occasions, once by

defense counsel and once by Appellant, does not amount to attorney misconduct.

First, the statements were fleeting and admonitions were given by the court.

Second, defense counsel moved on after the second use of the term and it was

-5- never mentioned again. Third, we do not agree that the term “unit 1” is so

common as to improperly influence the jury to infer that Appellant was the cause

of the accident. While the use of the term was improper, we do not believe it

influenced the jury to such a degree as to require a new trial. See Risen v. Pierce,

807 S.W.2d 945, 949-50 (Ky. 1991). The trial court did not err in denying the

motion for a new trial based on this issue.

Appellant’s second argument is that he was denied a fair trial because

he was not given certain data from Appellee’s expert witness during discovery.

Appellant categorizes this as attorney misconduct, for failing to turn over

discoverable material, and as the trial court’s abuse of discretion, in allowing

Appellee’s expert to testify over Appellant’s objection.

Prior to trial, both parties revealed their experts and expert reports

were exchanged.

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Related

Risen v. Pierce
807 S.W.2d 945 (Kentucky Supreme Court, 1991)
Clement Brothers Construction Co. v. Moore
314 S.W.2d 526 (Court of Appeals of Kentucky (pre-1976), 1958)
Gibson v. Fuel Transport, Inc.
410 S.W.3d 56 (Kentucky Supreme Court, 2013)
Davidson v. Commonwealth
548 S.W.3d 255 (Missouri Court of Appeals, 2018)

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John McGaughey v. Jenny Warnick, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-mcgaughey-v-jenny-warnick-kyctapp-2023.