A Georgia Court of Appeals panel has affirmed an $8.5 million judgment arising from a 2020 tractor-trailer crash in Spalding County, rejecting a trucking company’s arguments that the trial court improperly admitted evidence during a trifurcated proceeding. The verdict favored plaintiff Lewis Bennett, who alleged he suffered permanent spinal harm after being forced off the roadway and into a guardrail when another commercial driver lost lane control during a medical emergency. The appellate decision addresses how Georgia courts evaluate relevance and prejudice when causation and fault are tried separately from damages, and it also sustains a statutory attorney-fee award tied to a finding of bad faith.
Collision Allegations and Medical Emergency
Court filings and the appellate opinion describe a roadway encounter between two commercial trucks that culminated in Bennett’s vehicle being pushed onto the shoulder and then into a guardrail. The lawsuit alleged that James Evans, who was driving for Transcontinental Carriers Inc., passed Bennett and then failed to maintain his lane, forcing Bennett off the road. Bennett claimed the crash resulted in a permanent spinal injury, and the jury ultimately found Evans 30% at fault and Transcontinental 70% liable.
The opinion further states that Evans had Type 1 diabetes and had not administered insulin for two days before the incident. The record reflected that he was experiencing a medical emergency at the time of the collision and was in diabetic shock. Evans later died about a year after the crash, according to the panel. The case later raised a separate evidentiary dispute over whether the jury could hear evidence describing the development and persistence of Bennett’s injuries during the trial’s initial phase.
Trial Structure, Disputed Evidence, and the Causation Ruling
The case was tried in a trifurcated format. The first phase addressed causation and fault, while the second phase addressed damages. On appeal, Transcontinental argued that the trial court allowed Bennett to introduce evidence during phase one that belonged in the damages phase, contending the evidence went beyond the limited scope of causation and fault. The company’s position was that describing how Bennett’s condition progressed or persisted improperly invited the jury to consider damages before reaching threshold determinations.
The appellate panel disagreed and held that the evidence was not improperly admitted. In its analysis, the court emphasized that the jury’s causation task required a necessarily broad assessment of relevant facts to decide whether the alleged negligence caused the plaintiff’s injuries. The opinion noted that Transcontinental conceded the governing rule for trifurcated personal injury trials required the jury, in phase one, to determine whether Bennett sustained a spinal cord injury as a result of the collision. From there, the court accepted that this fundamental injury could be connected to other alleged symptoms, including ongoing neurological deficits and bladder dysfunction, making related evidence relevant to causation rather than an impermissible preview of damages.
Verdict, Attorney Fees, and the Bad-Faith Finding
The Spalding County jury awarded Bennett $7 million in damages and $1.55 million in attorney fees, for a total of $8.5 million. The verdict form also reflected the allocation of responsibility between the driver and the employer: Evans was found 30% at fault, while Transcontinental was found 70% liable. After the trial, Transcontinental sought appellate relief from the liability determination and from the fee award, focusing on evidentiary limits in the first phase and on the statutory basis for shifting fees.
The panel upheld the attorney-fee award under O.C.G.A. § 13-6-11, which permits recovery of fees when the opposing party acts in bad faith. The opinion concluded that the record supported the jury’s bad-faith determination, citing what the panel described as Evans’ ‘history of conscious disregard’ for the dangers associated with driving without taking his medication. The appellate court found the evidence sufficient to sustain the fee award and declined to disturb the jury’s determination. The appellate court treated that history as sufficient to sustain a bad-faith finding under the statute and declined to disturb the jury’s award. Bennett was represented by Scholle Law and Charles Madden Cork III, while Transcontinental was represented by Gray Rust Moffett & Brieske LLP and Freeman Mathis & Gary LLP.
Appellate Disposition and Practical Implications
The decision was issued by a three-judge panel of the Court of Appeals of Georgia consisting of Judges Kenneth B. Hodges III, Anne Elizabeth Barnes, and Todd Markle. The panel affirmed the judgment, leaving intact both the apportionment of fault and the damages and fee totals reflected in the verdict. In addressing Transcontinental’s evidentiary challenge, the court treated the causation inquiry as fact-intensive and dependent on the jury’s ability to hear evidence necessary to decide whether the collision produced the specific injuries claimed.
Separately, the ruling illustrates how a bad-faith finding under O.C.G.A. § 13-6-11 can support an attorney-fee award alongside an underlying negligence claim. Beyond the parties, the opinion offers guidance for litigants in trifurcated personal injury trials on how courts may draw the boundary between causation evidence and damages evidence when the existence and nature of an injury are themselves contested.
