Brumley v. Keech

This case stemmed from an accident involving an automobile and a tractor-trailer. Appellants, the driver of the automobile and his wife, filed suit against Appellees, the driver of the truck, the individual who leased the truck, and the owner of the truck, alleging negligence and requesting punitive damages for alleged violations of the Federal Motor Carrier Safety Regulations (FMCSR). Before trial, the circuit court entered an order excluding evidence of Appellees' failure to conduct a post-accident drug-and-alcohol testing. Appellees also asked to bifurcate the proceedings to exclude from the compensatory-damages phase of the trial evidence that was relevant only to punitive damages, but the circuit court did not address the motion. At the conclusion of Appellants' case, the circuit court granted Appellees' motion for directed verdict with regard to punitive damages. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in excluding evidence that Appellees failed to comply with the post-accident-testing requirements of the FMCSR; and (2) Appellants' second argument that the circuit court erred in granting Appellees' motion for directed verdict on punitive damages, which was premised on bifurcation, was not appropriate, as an opinion the Court could offer would only be advisory. View "Brumley v. Keech" on Justia Law