HomeMy WebLinkAbout97-6727 civilKAREN FLICKINGER,
INDIVIDUALLY AND IN HER
CAPACITY AS
ADMINISTRATRIX OF THE
ESTATE OF KRISTINA R.
FEHRENBACH, DECEASED,
Plaintiff
go
SARAH R. CHAPMAN, ROCK
CHAPMAN, DENNIS JAMES
WONDER, and WONDERS
AUTO REPAIR,
Defendants
go
PAUL FLICKINGER,
Additional
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
·NO. 97-6727 CIVIL TERM
· CIVIL ACTION- LAW
·
IN RE- PI~AINTIFF'S POST TRIAL MOTIONS
AS TO DEFENDANT WONDER ONLY
AND NOW, this
BEFORE GUIDO~ J:
ORDER OF COURT
~ day of JUNE, 2001, Plaintiff's Post Trial Motions are
DENIED.
Edward E. Guido, J.
David W. Knauer, Esquire
Dennis E. Reinaker, Esquire
Thomas E. Brenner, Esquire
KAREN FLICKINGER,
INDIVIDUALLY AND IN HER
CAPACITY AS
ADMINISTRATRIX OF THE
ESTATE OF KRISTINA R.
FEHRENBACH, DECEASED,
Plaintiffs
Vo
SARAH R. CHAPMAN, ROCK
CHAPMAN, DENNIS JAMES
WONDER, and WONDERS
AUTO REPAIR,
Defendants
Vo
PAUL FLICKINGER,
ADDITIONAL
DEFENDANT
· 1N THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
o
·
:
:
· NO. 97-6727 CIVIL TERM
:
:
·
·
' CWIL ACTION- LAW
o
IN RE' PLAINTIFF'S POST TRIAL MOTIONS
AS TO DEFENDANT WONDER ONLY
BEFORE GUIDO, J.
OPINION AND ORDER OF COURT
This tragic case involved the death of a young child who was struck and killed by
an automobile operated by defendant Chapman. Plaintiff alleged that the accident was
caused by defective brakes on the Chapman vehicle. She brought this action against
defendant Chapman as the driver of the vehicle and defendant Wonder as the mechanic
who had recently inspected it. The defendants alleged that Mrs. Chapman did not have
the opportunity to apply her brakes because the child darted into the path of her vehicle.
97-6727 CIVIL TERM
The jury apparently agreed with the defendants. After a three-day trial, it returned
a verdict in which it found that defendant Chapman was not negligent. While it found
that defendant Wonder was negligent, it also found that his negligence was not a
substantial factor in causing the accident.
Plaintiff filed post trial motions in connection with the verdict as it relates to
defendant Wonder.~ We directed plaintiff's counsel to file a brief in support of the post
trial motions. The brief raises the following issues:
1 .) The Honorable Court erred when it allowed the fact witnesses to give
opinion testimony to a situation of which they had little or no
knowledge.
2.) The Defendant Wonder's guilty plea should have been admitted into
evidence.
3.) The video containing family photographs of Kristina should have been
allowed as admissible evidence.
4.) The jury should have been charged that the Defendant Wonder's
violation of the regulations of the Pennsylvania Department of
Transportation's was negligence per se
5.) The Court erred when it charged the jury on contributory negligence
as to the Defendant Wonder because his conduct was an intentional
tort.
6.) If the Court grants a new trial, the jury's decision that Defendant
Dennis James Wonder was negligent is already established because it
was fully and fairly litigated.
"Plaintiff's Brief in Support of Post Thai Motions Directed to the Defendant Dennison
James Wonder Only," p. 3.2 Defendant Wonder has filed a reply brief. This matter is
now ready for disposition.
~ Apparently a high/low agreement precludes the filing of post trial motions in connection with the verdict
as it relates to defendant Chapman.
2 There were additional issues raised in plaintiff's post trial motion. However, since they were not briefed,
they are deemed to have been abandoned. See Local Rule 210-7.
97-6727 CIVIL TERM
DISCUSSION
Since the jury found that defendant Wonder was negligent, issues 2, 4, and 5 are
rendered moot. Since the jury found that defendant Wonder's negligence was not a
substantial factor in causing the accident, issue three (3) is rendered moot. Since
plaintiff's request for a new thai will not be granted, issue six (6) is rendered moot. We
will address the remaining issue.
Plaintiff argues that we were erred in allowing one lay witness to give opinion
testimony and refusing to allow such testimony by another lay witness. She points out
that we allowed the following exchange between defendant Wonder's counsel and a fact
witness'
Q. From what you observed, was there any opportunity for Mrs. Chapman
to avoid this accident?
A. No. I'm not an expert, but, no, I don't think so.
Therefore, she argues that we should have allowed another fact witness to answer the
following question asked by her counsel.
Q. If she needed a couple seconds to cross the road and the brake
pumping routine took even more seconds, she could have gotten across
the road?4
We note that plaintiff's counsel did not object to the opinion question posed by
defense counsel. Our appellate Courts have held it to be "fundamental that the parties in
a civil trial make timely and specific objections to alleged violations of evidentiary or
trial procedure." Boyle v. Steiman, 429 Pa. Super. 1, 20, 631 A.2d 1025, 1035 (1993).
Failure to do so results in a waiver of the issue. Id.
3 Notes of Testimony, p. 251.
4 Notes of Testimony, p. 330.
97-6727 CIVIL TERM
However, waiver notwithstanding, we are satisfied that the question posed by
defendant's counsel was proper, while that posed by plaintiff's counsel was not. Pa. Rule
of Evidence 701 states:
OPINION TESTIMONY BY LAW WITNESSES
If the witness is not testifying as an expert, the witness' testimony in the
form of opinions or inferences is limited to those opinions or inferences
which are rationally based on the perception of the witness and helpful to
a clear understanding of the witness' testimony or the determination of a
fact in issue.
The question asked by defense counsel came within the role. He merely requested an
eyewitness to the accident to give her opinion as to whether there was any chance for the
defendant to react to avoid striking the young girl who had darted out in front of her. On
the other hand, the question posed by plaintiff's counsel required the witness to assume
certain facts. An opinion by a lay witness based upon assumed facts goes well beyond
what is permissible under Pa. R.E. 701.
For the reasons set forth above, plaintiff's request for a new trial will be denied.~
ORDER OF COURT
AND NOW, this 1sT day of JUNE, 2001, Plaintiff's Post Trial Motions are
DENIED.
By the Court,
/s/Edward E. Guido
Edward E. Guido, J.
5 The plaintiff also requested judgment n.o.v. While she did not brief the issue, we note that the evidence at
trial was not such that a verdict for plaintiff"was beyond peradventure." Moure v. Raeuchle, 529 Pa. 394,
403,604 A.2d 1003, 1007 (1992). In other words, the evidence did not clearly establish "that no two
reasonable minds could disagree that the outcome should have been rendered in favor of the (plaintiffs)."
Id.
97-6727 CIVIL TERM
David W. Knauer, Esquire
411-A East Main Street
Mechanicsburg, Pa. 17013
Dennis E. Reinaker, Esquire
1347 Fmitville Pike
Lancaster, Pa. 17601
Thomas E. Brenner, Esquire
320 Market Street, Strawberry Square
P.O. Box 1268
Harrisburg, Pa. 17108-1268
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