Carrier v. Starnes
North Carolina Court of Appeals
463 S.E.2d 393 (1995)

- Written by Sean Carroll, JD
Facts
Minnie Carrier (plaintiff) was injured in a car accident with Clyde Starnes (defendant). Carrier sued Starnes to recover for her injuries. At trial, Starnes introduced a post-accident video of Carrier that had been taken by Kenneth Holmes, an investigator for Starnes’s insurance company. The insurance company had hired Holmes to surveil Carrier and record the surveillance. Holmes testified that he recorded Carrier performing various activities, while paying specific attention to areas of her body that she claimed were injured in the accident. The trial court permitted Carrier to cross-examine Holmes about his financial arrangement with the insurance company as a means of showing his bias. Starnes appealed.
Rule of Law
Issue
Holding and Reasoning (Cozort, J.)
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