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Hendrix v. Burns
Maryland Court of Appeals
205 Md. App. 1 (2010)
Facts
Charles Burns (defendant) ran a stoplight and caused a car wreck that injured Marjorie Hendrix (plaintiff). Hendrix’s car was so badly damaged in the wreck that rescuers had to extract her from the vehicle using a jaws-of-life tool. At the time of the wreck, Hendrix believed she was going to die. Hendrix suffered extreme pain, emotional trauma, and depression as a result of her injuries. After the accident, Hendrix learned that Burns was a drunk driver who had been chasing another car as part of a road-rage incident and had attempted to leave the scene after hitting Hendrix’s car. Learning these facts caused Hendrix additional emotional distress. Hendrix sued Burns, who admitted liability. At a jury trial to determine damages, the judge granted Burns’s motion in limine to exclude evidence that he had been drinking, that he was involved in a road-rage incident, and that he attempted to leave the scene of the wreck. The jury found for Hendrix, and she appealed, arguing that the trial court had erroneously excluded evidence relevant to her mental-distress damages.
Rule of Law
Issue
Holding and Reasoning (Eyler, J.)
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