Earlier this month, a state appellate court issued a written opinion in a car accident case in which the plaintiff’s vehicle was struck by a drunk driver. The case required the court to determine if the defendant’s prior convictions for driving under the influence could be admitted at trial. Ultimately, the court concluded that the prior convictions were relevant to the punitive damages determination and thus should be admitted for that limited purpose.
The Facts of the Case
The plaintiff was driving to work on the highway when suddenly, the defendant’s vehicle crossed over into the plaintiff’s lane of traffic. The two vehicles collided head-on. It was later determined that the defendant had a blood-alcohol content of .18, which is over twice the legal limit.
The plaintiff filed a personal injury lawsuit against the defendant. During the plaintiff’s case, he attempted to introduce evidence that the defendant had been convicted of driving under the influence on two prior occasions, once in 1996 and another time in 1983. The court allowed the evidence to be admitted over the defendant’s objection. Ultimately, the jury awarded the plaintiff over $1,500,000.
The Defendant Appeals
The defendant appealed, arguing that the lower court’s decision to allow the prior DUI convictions into evidence was improper. Specifically, the defendant claimed that the prior convictions were not relevant to the resolution of the case and that even if the prior convictions were relevant, their relevance was outweighed by the prejudice they caused. In other words, the defendant claimed that the evidence was unfair because it swayed the minds of the jury beyond the manner for which it was intended.
The appellate court affirmed the lower court’s decision to admit the evidence and affirmed the jury’s verdict. The court explained the evidence of the prior convictions was not relevant to the jury’s determination of whether the defendant was liable for the plaintiff’s injuries, nor was it relevant to the determination of compensatory damages. However, the prior convictions were relevant to the determination of punitive damages.
Punitive damages are appropriate when a party’s behavior is especially egregious. Here, the court held that the fact that the defendant had twice been convicted of driving under the influence may tend to prove that the defendant did not “learn his lesson” after the first two convictions, which a jury may consider when determining whether to issue punitive damages.
Have You Been Injured in a Maryland DUI Accident?
If you or a loved one has recently been injured in a Maryland DUI accident, you may be entitled to monetary compensation. The skilled personal injury and wrongful death attorneys at the law firm of Lebowitz & Mzhen Personal Injury Lawyers have extensive experience holding negligent drivers responsible for their actions. We understand what it takes to recover compensation for our clients, and we are prepared to take your case to trial if we cannot reach a fair settlement with the defendants. Call 410-654-3600 today to schedule a free consultation with a dedicated personal injury attorney.
More Blog Posts:
Court Determines Puddle of Rainwater Did Not Constitute “Dangerous Condition” in Premises Liability Case, Maryland Accident Law Blog, April 24, 2017.
Plaintiff’s Failure to Comply with Procedural Requirement Results in Dismissal of Lawsuit, Maryland Accident Law Blog, May 8, 2017.