Tameko Sawyer v. Randy C. Lucas

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 11, 2024
DocketA-3832-21
StatusUnpublished

This text of Tameko Sawyer v. Randy C. Lucas (Tameko Sawyer v. Randy C. Lucas) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tameko Sawyer v. Randy C. Lucas, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3832-21

TAMEKO SAWYER,

Plaintiff-Appellant,

v.

RANDY C. LUCAS, HICKS PAVING, LLC, and HICKS SEPTIC & PORTABLE TOILETS, LLC,

Defendants-Respondents. _____________________________

Argued December 5, 2023 – Decided January 11, 2024

Before Judges Whipple, Mayer and Paganelli.

On appeal from the Superior Court of New Jersey, Law Division, Middlesex County, Docket No. L-3880-17.

Michael James Confusione argued the cause for appellant (Hegge & Confusione, LLC, attorneys; Michael James Confusione, of counsel and on the briefs).

Michael J. Marone argued the cause for respondents (McElroy, Deutsch, Mulvaney & Carpenter, LLP, attorneys; Michael J. Marone, of counsel and on the brief; Sandra D. Lovell, on the brief).

PER CURIAM

Plaintiff, Tameko Sawyer, appeals the denial of her motions for a new trial

on damages or additur. At the conclusion of trial, the trial court explained

plaintiff's motions were untimely and, even on the merits, the jury's verdict did

not shock the conscience. We affirm.

On June 17, 2016, plaintiff suffered an injury to her neck, lower back, and

shoulder. Defendant Randy Lucas was driving a tractor-trailer owned by

defendant Hicks Paving, LLC and Hicks Septic & Portable Toilets, LLC

(collectively defendants). Plaintiff and Lucas were traveling on Route 78, when

the truck moved into plaintiff's lane, striking her car, causing it to slam into the

guardrail. The Emergency Medical Technician (EMT) who responded to the

scene documented plaintiff's vehicle had minor damage. Plaintiff refused

transport to the hospital and when initially examined at the scene only

complained of head pain. Plaintiff did tell the EMT she had a previous back

injury.

After the accident, plaintiff went to the hospital where she was evaluated

for head, neck, and back injuries. She suffered disc herniations and bulges in

her neck and underwent five separate surgeries.

A-3832-21 2 On June 23, 2017, plaintiff filed a complaint then an amended complaint

naming defendants. The trial began on May 31, 2022.

During trial, defendants filed in limine motions to exclude admission of

plaintiff's Day in the Life video and her recently supplied supplemental

discovery. The court barred both.

Plaintiff testified she first experienced pain in her head following the

accident. She also testified she left the hospital before being fully evaluated.

Plaintiff, along with treating physicians, testified about the conservative pain

management she underwent for an older, unrelated back injury. Throughout the

trial, the parties and their experts disagreed about the genesis of plaintiff's back

injury and whether it was caused or exacerbated by the accident.

The jury found defendants' negligence proximately caused the accident

and plaintiff's injuries. The jury awarded $400,000 in damages.

Plaintiff moved for a new trial on damages or additur, which the court

denied on procedural and substantive grounds. The trial court rendered its oral

decision noting the motion had been filed three days late but considered its

merits. The court concluded the jury's verdict did not shock the conscience, the

jury was properly advised as to the information it could consider as evidence,

took notes, and based on the evidence, weighed the facts, deliberated, considered

A-3832-21 3 the information, and arrived at the damages award. The court also rejected the

argument the award was manifestly unjust. This appeal followed.

We review a trial court's decision on a motion for additur under an abuse

of discretion standard. Tronolone v. Palmer, 224 N.J. Super. 92, 104 (App. Div.

1988). The same standard is used when a trial court admits or excludes evidence

as we grant substantial deference to a trial court's discretion on evidentiary

rulings. Griffin v. City of East Orange, 225 N.J. 400, 413 (2016).

Plaintiff first argues the court should have allowed the jury to observe her

Day in the Life video as it was relevant, probative, and accurately represented

the impact of her injuries. She argues the trial court misapplied N.J.R.E. 401

and 403 and did not properly weigh the evidence nor consider its relevancy.

The barred video was five minutes long and recorded about a year and a

half after the sustained injuries, but just eight days after she had back surgery

and still required significant assistance with activities of daily living. Plaintiff

argues the video was relevant to support her claim for future medical costs and

the pain, suffering and loss of enjoyment she endured.

We apply an abuse of discretion standard to questions of whether the

probative value of evidence is "substantially outweighed by its prejudicial

nature" under Rule 403. Green v. N.J. Mfrs. Ins. Co., 160 N.J. 480, 492 (1999).

A-3832-21 4 Under N.J.R.E. 403 "relevant evidence may be excluded if its probative value is

substantially outweighed by the risk of: (a) undue prejudice, confusion of issues,

or misleading the jury; or (b) undue delay, waste of time, or needless

presentation of cumulative evidence."

Day in the Life videos are permitted when a trial court finds them relevant,

probative, and an accurate representation of injuries. Robert Schiavo v. Owns-

Corning Fiberglas Corp., 282 N.J. Super. 362, 368 (App. Div. 1995). Plaintiff

argues the video was necessary to demonstrate her difficulty in day-to-day

activities and the inability to present it deprived her the right to show the jury

evidence of pain and suffering.

Plaintiff's argument is unavailing. In our view, the trial court did not

abuse its discretion in excluding the videotapes. In Schiavo, we stated that in

addition to being relevant and probative, the videotape needs to be "an accurate

representation of the impact of the injuries upon the subject's day-to-day

activities." 282 N.J. Super. at 368.

Unlike in Schiavo, where the injuries rendered the victim unable to

function, plaintiff's video was taken during her recuperation from a surgery,

instead of day-to-day life post-accident. As such, the trial court here, did not

err finding the focus of the videotape was plaintiff's recovery from surgery as

A-3832-21 5 opposed to her day-to-day life and was not an accurate representation of the

continued impact of her injuries. Plaintiff testified during the trial regarding the

extent of her injuries as a result of the accident and the impact of those injuries.

Plaintiff next argues the trial court abused its discretion precluding recent

amendments to discovery 1 and not allowing her to present updated medical

information at trial. She contends the updated medical records were not a

surprise, and this information did not prejudice defendants' ability to respond,

and the evidence was pivotal. She argues the trial court's decision, declining to

allow the discovery, significantly limited her ability to present her claim for

damages.

A trial court's discretion in excluding evidence is broad. State v.

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Related

Green v. New Jersey Manufacturers Insurance
734 A.2d 1147 (Supreme Court of New Jersey, 1999)
State v. Sands
386 A.2d 378 (Supreme Court of New Jersey, 1978)
Jastram Ex Rel. Jastram v. Kruse
962 A.2d 503 (Supreme Court of New Jersey, 2008)
Ratner v. General Motors Corp.
574 A.2d 541 (New Jersey Superior Court App Division, 1990)
Schiavo v. Owens-Corning Fiberglas
660 A.2d 515 (New Jersey Superior Court App Division, 1995)
Johnson v. Scaccetti
927 A.2d 1269 (Supreme Court of New Jersey, 2007)
Tronolone v. Palmer
539 A.2d 1224 (New Jersey Superior Court App Division, 1988)
Danny Caicedo v. Fabian Caicedo
110 A.3d 969 (New Jersey Superior Court App Division, 2015)
Tonique Griffin v. City of East Orange (074937)
139 A.3d 16 (Supreme Court of New Jersey, 2016)
Ramon Cuevas v. Wentworth Group(075077)
144 A.3d 890 (Supreme Court of New Jersey, 2016)

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Tameko Sawyer v. Randy C. Lucas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tameko-sawyer-v-randy-c-lucas-njsuperctappdiv-2024.