Shaneyfelt v. Byram

2020 Ohio 1406
CourtOhio Court of Appeals
DecidedApril 10, 2020
Docket2019-CA-9
StatusPublished

This text of 2020 Ohio 1406 (Shaneyfelt v. Byram) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shaneyfelt v. Byram, 2020 Ohio 1406 (Ohio Ct. App. 2020).

Opinion

[Cite as Shaneyfelt v. Byram, 2020-Ohio-1406.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT DARKE COUNTY

: DOUGLAS A. SHANEYFELT : : Appellate Case No. 2019-CA-9 Plaintiff-Appellee : : Trial Court Case No. 2018-CV-141 v. : : (Civil Appeal from ROBERT J. BYRAM, et al. : Common Pleas Court) : Defendant-Appellant :

...........

OPINION

Rendered on the 10th day of April, 2020.

KENNETH J. IGNOZZI, Atty. Reg. No. 0055431 and BRIAN M. HAREN, Atty. Reg. No. 0091188, 131 North Ludlow Street, Suite 1400, Dayton, Ohio 45402 Attorneys for Plaintiff-Appellee

JUDD R. UHL, Atty. Reg. No. 0071370 and PATRICK B. HEALY, Atty. Reg. No. 0083756, 201 East Fifth Street, Suite 1900, Cincinnati, Ohio 45202 Attorneys for Defendant-Appellant

.............

HALL, J. -2-

{¶ 1} Robert J. Byram appeals from the trial court’s entry sustaining appellee

Douglas A. Shaneyfelt’s motion for a new trial after a jury verdict for Byram in this

personal-injury action.

{¶ 2} Byram advances two assignments of error. First, he contends the trial court

erred in finding that his use of demonstrative evidence at trial materially prejudiced

Shaneyfelt and necessitated a mistrial. Second, he claims the trial court further erred in

barring him from using his accident-reconstruction expert, or anyone from his expert’s

firm, in future proceedings in this case.

{¶ 3} The record reflects that Shaneyfelt was driving his pick-up truck south on

State Route 49 around 11:30 p.m. on March 14, 2017. The rural road was not illuminated,

and Shaneyfelt was travelling between 50 and 55 miles per hour on cruise control. At the

same time, Byram was backing a tractor-trailer into his driveway on State Route 49. While

still at least a quarter of a mile away, Shaneyfelt saw Byram’s headlights in the distance.

At trial, Shaneyfelt testified that he saw only headlights facing him until he got close to the

tractor-trailer. Between 66 and 90 feet away, Shaneyfelt hit his brakes but was unable to

stop before striking the side of the tractor-trailer, which was blocking both lanes of travel.

Shaneyfelt’s most significant injury from the accident was a left shoulder rotator cuff tear.

For his part, Byram testified that he could see approximately one mile on the straight, flat

road and that he looked for traffic before performing his backing maneuver, which took

him just over a minute to perform. The record establishes that it was not unlawful for

Byram to back into his driveway and that the tractor-trailer was equipped with all required

reflectors, lights, and conspicuity markings, and he had turned on his flashing hazard -3-

lights. Byram also presented evidence that Shaneyfelt’s pick-up truck was critically low

on brake fluid. Finally, Byram presented evidence that his headlights would not have been

shining directly at Shaneyfelt continuously during the backing maneuver, which was

almost completed at the time of the accident. Byram testified that his headlights would

not have pointed directly at Shaneyfelt for “very long at all.” Shaneyfelt’s own expert

witness agreed that Byram’s headlights would have been moving “all over the place”

during the backing maneuver.

{¶ 4} After hearing all of the evidence, a jury returned a verdict in favor of Byram.

Through interrogatories, the jury found that Shaneyfelt had failed to prove, by the

preponderance of the evidence, that negligence by Byram had caused the accident.

Despite the fact that the first interrogatory contained instructions that lack of negligence

by the defendant made the other interrogatories unnecessary, the jury proceeded. The

jury also found that Byram had proven, by the preponderance of the evidence, that

negligence by Shaneyfelt had caused the accident. Finally, with regard to potential

comparative negligence, the jury found Shaneyfelt 100 percent negligent and Byram zero

percent negligent.

{¶ 5} Following the jury’s verdict, Shaneyfelt moved for a new trial. He raised two

issues. One concerned the trial court’s allowing defense counsel to use, as demonstrative

evidence at trial, three computer-simulated images purporting to show how Byram’s

tractor-trailer would have appeared to Shaneyfelt from 600 feet, 400 feet, and 250 feet

away. Shaneyfelt argued that the three large blowups had not been timely produced in

discovery and that “these alleged demonstrative exhibits of what Mr. Shaneyfelt could

see as he approached the area of the intersection, the key issue in the case (discernibility -4-

at night time) were inflammatory, prejudicial, and clearly admitted, over objection, and

without basis.” (Motion for New Trial at 5.) The other new-trial issue involved defense

counsel referencing Shaneyfelt’s non-use of a seat belt.

{¶ 6} The trial court sustained the new-trial motion based on use of the

demonstrative evidence by Byram’s accident-reconstruction expert, Ashley Dunn. The

trial court reasoned:

Mr. Dunn prepared three reconstructive diagrams of the crash scene

which were eventually presented during trial. The diagram and his testimony

purported to put the jury in the position to view the impending collision from

Mr. Shaneyfelt’s viewpoint at various distances prior to the point of impact.

These diagrams were not prepared until after the discovery cut-off date;

their existence was only disclosed to Plaintiff on May 17th [four days before

trial].

Clearly, this late disclosure of new material clearly violated the

Court’s Scheduling Order filed June 26, 2018 which set a deadline of April

12, 2019 for the disclosure of discoverable materials.

However, as stated by [King v. Niswonger, 2d Dist. Darke No. 2013-

CA-1, 2014-Ohio-859], violations of deadlines alone are not grounds for

exclusion of evidence. Instead, the opposing party must also be “materially

prejudiced” by the evidence. When presented with the discovery problem

during trial, the Court was compelled to determine whether there was any

material prejudice in the diagrams. Aware of the approaching evidentiary

conundrum, and before allowing presentment of the exhibits and related -5-

testimony, the Court cautioned the jury that it may hear evidence that might

later be stricken. Allowing the testimony and subjecting it to cross-

examination was the best way for the Court during trial to determine whether

Plaintiff would be materially prejudiced by admission of the exhibits and

related testimony.

The Court agrees with the Defendant’s citation to State v. Jones, 135

Ohio St.3d 10, 984 N.E.2d 948 (2012) which stands for the proposition that

demonstrative evidence is admissible if relevant and substantially similar to

the object or occurrent [sic] being represented.

In this case, the demonstrative evidence runs afoul of Jones. The

primary transgression is the misrepresentation of facts by Mr. Dunn when

making the diagrams. Specifically, Mr. Dunn failed to measure lumens of

the lights on the Defendant’s tractor-trailer unit and lumens of the headlights

of the Plaintiff’s pick up truck. Since lumens measure the amount of light

being emitted from a device (aka brightness), and since no measurements

were taken, it is impossible for Mr. Dunn to accurately represent the facts

of the motor vehicle collision involved herein in those diagrams. His reliance

on industry standards and textbook studies may be accepted for a scientific

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Related

State v. Jones
2012 Ohio 5677 (Ohio Supreme Court, 2012)
King v. Niswonger
2014 Ohio 859 (Ohio Court of Appeals, 2014)
Evans v. Thobe
2011 Ohio 3501 (Ohio Court of Appeals, 2011)
Miller v. Remusat, 07-Ca-20 (5-9-2008)
2008 Ohio 2558 (Ohio Court of Appeals, 2008)
Fada v. Information Systems & Networks Corp.
649 N.E.2d 904 (Ohio Court of Appeals, 1994)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
Pond v. Leslein
647 N.E.2d 477 (Ohio Supreme Court, 1995)

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2020 Ohio 1406, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shaneyfelt-v-byram-ohioctapp-2020.