The Accident Reconstruction And Biomechanical Expert
The AccidentReconstructionand BiomechanicalExpertThe number of experts used in some personal injurymatters can be staggering. Even routine, soft-tissue injurycases sometimes involve multiple liability and medicalexperts. Often counsel will go overboard, hiring expertwitnesses when a simpler approach wouldsuffice. However, in commercial motor carrier collision cases, using accident reconstruction and biomechanical experts isindispensable to an effective defense strategy, especially in serious injury and wrongful death cases. It is hard to imagine atrucking company involved in these typesof personal injury cases not having anaccident reconstructionist as a memberof a rapid response team, which investigates the crash scene and collects evidenceto describe and recreate how a collisionoccurred. Likewise, it is not uncommonfor a trucking company to retain a biomechanical engineer to understand how animpact caused the injuries sustained tobegin to develop a working defense theoryto a potential claim against one of its drivers, even if someone has not filed a suit.However, defense counsel would beshortsighted to use these experts only ona rapid response team or during a pre-suitinvestigation. These experts bring morevalue to a case than merely collision analysis or identifying the liability of each party.They can assist with assessing case value,devising a defense theory, determininghow a collision occurred, and attacking aplaintiff's experts at depositions to set upDaubert and summary judgment motions.This article addresses briefly the roles thatthese experts can play, and then focuses onhow they can assist defense counsel withthe ultimate goals of excluding plaintiff'sexperts from testifying at trial, or betteryet, obtaining summary judgment.The Role of an AccidentReconstructionistAccident reconstructionists are criticalmembers of every trucking company andlaw firm's rapid response team. Theseexperts, who are often engineers or formerlaw enforcement officers, are responsiblefor collecting, cataloguing, and analyz-
Iing vehicle crash scene data to describethe events that led to an impact betweenyour client's commercial vehicle and othervehicles, pedestrians, or stationary objectsinvolved in a collision. Arriving on thescene quickly to collect evidence beforeit disappears or is destroyed is crucial todetermining how an accident occurredand who may be at fault. With law enforcement and emergency responders preoccupied with clearing a scene and treatinginjured motorists, an immediate responseis imperative to document the evidence ofa crash, especially in adverse weather conditions. In fact, depending on the size ofyour state, it may make sense to have twoto three accident reconstructionists on theteam to expedite travel to the scene andto minimize travel costs associated withsubsequent trips to inspect the vehiclesinvolved in a crash, which never occur onthe day of a crash. More importantly, youraccident reconstructionists can help you tobegin developing a defense strategy immediately to the eventual lawsuit that willresult. Once the data is collected and evaluated, your experts can reconstruct or recreate how a collision occurred.However, an accident reconstructionistand his or her team can serve a function beyond just gathering scene evidence. Whilethe first hours are the most critical to preserving collision-scene evidence successfully, an accident reconstruction team canalso provide a valuable service to your client by gaining access to information onlyin possession of the investigating police department. The accident reconstructioniststhat we typically use often have assistantson staff who are former law enforcementpersonnel, many of whom served as fatalcrash investigators. Beyond visiting a sceneto help with evidence collection and surveying the vehicles involved in a crash, theserapid response team members can gain access to evidence that attorneys have to waitweeks or months to obtain. For example, aformer-police officer turned-accident reconstructionist assistant will have a mucheasier time convincing the investigatingpolice officers to relay information about acrash before official reports are completedthan we, the lawyers for a trucking company involved in a collision, can. Such anassistant can sometimes obtain the namesof fact witnesses or the locations of towedvehicles or get a handle on the type of paperwork that you need to complete to obtainformal reports. In one case that we handlecurrently, when our accident reconstructionist's assistant, who is a former-New YorkCity Police Department fatal crash scene investigator, spoke with the officers who responded to the scene of a pedestrian fatality,we learned that the decedent was unresponsive within seconds of impact, thus allowing us to evaluate, well in advance of takingdepositions and receiving the medical andautopsy records, the potential value of thedecedent's family's claims.Technology, specifically "black boxes,"ECMs, EDRs, lane-changing devices, dashcams, and other devices, contain valuabledata about a crash that must be preserved.Your accident reconstructionist should bethe person to coordinate preserving anddownloading the electronic devices contained in your client's vehicle. Your accident reconstructionist should have expertknowledge on automobile electronic datarecorders found in automobiles, that is,how to preserve them and download thedata, the type of data that they contain, anddepending on the make and model of thevehicle, whether the vehicle contains anyother technology that might have recordedthe events leading to a crash such as lanechanging technology, accident avoidancetechnology, or air-bag deployment, amongothers. Further, your expert should be ableto point out anything that will adverselyaffect downloading the data or establishing a chain of custody. For example,sometimes, moving a tractor before downloading its data may alter the data.An accident reconstructionist shouldnot be forgotten after the evidence is collected or ignored until it is time to servean expert report. Pre-suit evaluation of acase for resolution or defense is what distinguishes commercial transportation collision cases, especially catastrophic injurycases, from other personal injury matters.An accident reconstructionist can helphere, too. A detailed and thorough analysisof the pre-crash behavior of the drivers, thepaths of the vehicles, their speed, and thedrivers' perception and reaction times willassist you when evaluating the potentialliability hurdles that your client will face ifsuit is filed. Your expert can run throughdifferent crash-scene scenarios, includingslowing down the speed of the vehicles andpedestrians to determine whether a collision could have been avoided, who had thebest and last opportunity to avoid a crash,what obstacles might have impeded thedrivers' abilities to avoid a crash, and othersite conditions that might have influencedthe events. An accident reconstructionistcan help you mold your defense strategy, Defense counsel wouldbe shortsighted to use theseexperts only on a rapidresponse team or duringa pre-suit investigation.determine how to deal with your driver,and educate your client on whether a caseis defensible at the outset.The Role of a Biomechanical ExpertBiomechanical engineers can help youunderstand how the forces associated witha collision affected the body of a victim andresulted in the sustained injuries. Biomechanical experts are mechanical engineerswith expertise, experience, and a courseof study in anatomy and physiology, medicine, and the interplay of different humanbody systems. Biomechanical experts studythe complex interaction between outsideforces on the human body and its systems and the nature, type, and characteristic injuries associated with the forces . Inmotor vehicle collision cases, these expertsexamine radiology images, radiographs,medical records, coroners' reports, autopsyreports and photographs, collision scenephotographs and measurements, surveysof the vehicles, and any simulation or animation prepared by an defense accidentreconstructionist of the vehicles involved ina crash. Armed with this information, theydetermine what forces were applied to thevehicles and the bodies to evaluate whetherthe resulting injuries are consistent withthe type and direction of forces applied.These experts can assist defense counsel during the earliest stages in a caseFor The Defense December 2014 73
TRUCKING LAWto formulate both liability and damagesstrategies, and, when appropriate, withpre-suit settlement strategies. A biomechanical expert can shed light on the directional path of a pedestrian moments beforean impact based on the nature of the injuries and the focal nature of the impact. Thisinformation often can help you determine,early on, whether to devise a comparative Your expert should beable to point out anythingthat will adverselyaffect downloading thedata or establishing achain of custody.negligence defense. In catastrophic cases,a biomechanical engineer's analysis andopinion on how injuries occurred is invaluable. Similar to an accident reconstructionist, a biomechanical engineer can help thedefense of a case in so many different ways.Deposition PreparationYour accident reconstruction and biomechanical experts can also help you prepare to depose plaintiffs, fact witnesses,and especially, plaintiff's experts. Giventhe sometimes sketchy qualifications andmethodology used by experts in thesefields, it is worthwhile to consult with yourexperts to develop a strategy to attack aplaintiff's experts' credentials and investigation of a collision to set up your Daubertchallenge and summary judgment motion.Preparation is imperative when deposing any witness, especially an expert witness. Before preparing for a deposition andcommitting yourself to an outline, establish the goals that you want to achievefrom the deposition, a wish list, or as oneof my partners calls it, a "Christmas list,"of admissions or answers to questions thatyou want or need to have before you finish the deposition. Your accident reconstructionist and biomechanical engineerwill have their own wish lists of informa-74 For The Defense December 2014tion that they would like to have for theirinvestigations, opinions, and reports. Askthem what they need from a deposition asyou prepare your list. On this list can betopics such as qualifications; CV; experience investigating motor carrier- automobile collision cases; causation; re-creation,simulation, or animation of the collisionsequence; Plaintiff's role in collision; Factors contributing to collision; Factors thatdid not contribute; and other issues relevant to your case. For biomechanical orhuman factors experts, you also mightwant to include topics specific to this discipline, such as point of impact; crush Injuries; trauma, and other topics. Once yourlist is complete, call your experts to discussstrategies to meet these goals.During this call, if you do not have italready, have your experts provide you withtheir view of a crash so that you intimatelyunderstand how the crash happened. Theattorney taking the deposition must understand the time, speed, and distance factors involved in a case; the perception andreaction times of your driver and the plaintiff; and any site conditions, such as treesor roadway surface, that may have influenced the drivers, among other issues. Thedeposing attorney should discuss the collision sequence with the defense expertsand engage in a dialogue that reinforcestheir mutual understanding of the crashdynamics and establishes the defense strategy of the case. Next, the dialogue shouldfocus on the methodology used by a plaintiff's expert to understand the expert's recreation of how an accident occurred. Beforewalking into the deposition conferenceroom, the deposing attorney has to be ableto "talk the talk" of a plaintiff's accidentreconstructionist, or to speak in the samevernacular as the plaintiff's accident reconstructionist, to depose the reconstructionist effectively.One of the first and most critical topics from a Daubert perspective is whethera plaintiff's accident reconstructionist isqualified to testify. In some cases, accidentreconstructionists will opine on issues in acase that are unrelated to the dynamics ofa crash. It is not uncommon for a formerpolice officer who served as a member ofa county or state crash investigation unitto opine both about how and why a crashhappened and that a driver and a companyviolated the Federal Motor Carrier SafetyRegulations (FMCSR) when serving as apaid consulting witness. If this happens, itis worthwhile at least to consult with a regulations expert to understand whether theplaintiff's accident reconstructionist hasthe experience, qualifications, and expertise to render an opinion on logbook violations. Merely reading the regulations anddeclaring a violation is not enough for awitness to opine that a violation occurredthat proximately caused a crash, thoughmany plaintiff accident reconstructionists try to do this. Nor does past experience conducting roadside checks of trucksat weigh stations qualify a former statetrooper as an expert on the FMCSR. Further, you can use your accident reconstructionist to develop questions that challengea plaintiff's expert's conclusions that anhour of service violation caused a driverto become fatigued or distracted, whichled to a crash. Any good accident reconstructionist can tell you that certain physical evidence found at a crash scene willindicate that a wreck was caused by a distracted driver. With this information, youcan challenge a plaintiff's expert's conclusions when the evidence does not exist.If a plaintiff's expert has limited his orher opinions to areas that meet the expert'squalifications and experience, your accident reconstructionist's role is to explainto you the gaps in the expert's investigation and subsequent recreation that youmight use to argue to a court that theexpert's opinion fails under Daubert. Forexample, in a case that we handled, ouraccident reconstructionist explained thatthe plaintiff's expert failed to calculate thedistance from the point of impact at whichour driver first should have perceived theplaintiff's vehicle. Additionally, our expertadvised us that our driver's reaction timewas consistent with generally acceptedreaction times, which the plaintiff's expertdid not account for. With this information,we deposed the plaintiff's expert at lengthon his investigation and the missing calculations, measurements, or recordingsof the time factors involved in the crash.These admissions formed the heart of ourDaubert challenge.This area of deposition preparation iscrucial for several reasons. First, once adeposing attorney understands a plain-
tiff's expert's report, methodology, andthe gaps in the methodology, the moreeffective the deposition will be. The attorney will be able to expose shortcomingsin the expert's analysis and the investigation's deficiencies and use them to place theexpert on the defensive during the deposition, which will help the attorney forcethe expert to back off some of his or herrendered opinions to induce the expert toagree with some of the defense's points.Once an expert starts agreeing with you onsome points, the expert often will concedeother points as well. Further, with an eyetowards the Daubert motion, understanding the gaps with the assistance of yourexperts will allow you to box a plaintiff'sexpert into concessions-whether stated ornot-that his or her conclusions are subjective beliefs about what happened and why,and not based on scientific methods in thefield of accident reconstruction or biomechanics. See Johnson v. Arkema, Inc., 685F.3d 452 (5th Cir. 2012) (expert cannot testify to subjective beliefs). Or with summary judgment as your goal, you can useyour expert to understand and then subsequently question a plaintiff's expert onthe fact that his or her opinions fall shortof establishing causation.Biomechanical experts play the samerole. The first question to ask is a simpleone: is the expert a qualified biomechanical expert? In many cases, we have foundaccident reconstructionists wearing twohats in the same case: serving both as anaccident reconstructionist and as biomechanical expert though they typically lackthe credentials and expertise in the fieldof biomechanical engineering. Next, withyour biomechanical expert's assistance,understand how the injuries occurred andwhether what happened caused the injuries sustained. A deposing attorney needsto understand how the component partor parts of a commercial vehicle that contacted a plaintiff's vehicle, or a plaintiffin a pedestrian case, could cause a traumatic brain injury, fractured pelvis, or spinal cord injuries. Your expert can evaluatea plaintiff's biomechanical expert's conclusions and explain to you whether the. expert's explanation of the crash dynamics matches the mechanism of injury andthe injuries ultimately sustained. This analysis is particularly critical in seatbelt cases.Your biomechanical expert might be ableto develop a working theory that a seatbeltfailure, and not the collision, was the substantial contributing factor and proximatecause of a plaintiff's injuries. This pointcould be important in two respects. First,this analysis and defense theory providesignificant cross-examination questions.Second, they potentially allow your clientto limit its liability and damages exposure.These objectives cannot be achievedwithout your expert teaching you about themechanics of how a plaintiff's injuries weresustained and how the plaintiff's expertfailed to recognize a potential alternativecause of the sustained injuries.Finally, have your experts prepare questions for you to ask. Your experts are inthe best position to draft the questionsthat they need answered to cross items offtheir wish lists. Further, they can evaluatea plaintiff's testimony in response to thesequestions to determine whether the plaintiff's "recollection" of the collision matchesthe physical evidence gathered at the scene.That they will also prepare questions to askof the expert witnesses almost goes withoutsaying. It is difficult to imagine deposinga plaintiff's expert with the hope of striking his or her opinions through Daubertwithout having a list of questions fromyour experts.The Daubert Motion-YourExpert as "Brief Writer"Federal Rule of Evidence 702 requiresplaintiff's experts, among other things,to be qualified, knowledgeable, and havetechnical expertise in the field on whichthey offer opinions. Further, it requiresan expert actually to reconstruct an accident and measure and calculate vehiclespeed, time, and distance to determine howan accident happened and who caused it.An accident reconstructionist who fails toreconstruct an accident should not be permitted to testify because he or she cannot satisfy the admissibility requirementsin Federal Rule of Evidence 702. The rulelikewise requires biomechanical expertsto evaluate various factors associated withthe collision-namely, the positions ofoccupants in the vehicles; the positionor the location of pedestrians in relationto the vehicles; restraint systems; vehiclestructures and their location in relation topedestrians-to determine how the resulting injuries were sustained. When theseexperts fail to do that, you should file aDaubert v. Merrell Dow Pharmaceuticals,Inc., 509 U.S. 579, 597 (1993), motion toexclude these experts from testifying.The Daubert motion has to distinguishbetween methodology arguments andcredibility arguments because the former It is worthwhile toconsult with your expertsto develop a strategy toattack a plaintiff's experts'credentials and investigationof a collision to set up yourDaubert challenge andsummary judgment motion.are proper for a court, as the gatekeeper, toconsider, while the latter are left for a juryto evaluate. Daubert, 509 U.S. at 590-91.The objective of the "gatekeeping" requirement is "to make certain that an expert,whether basing testimony upon professional studies or personal experience,employs in the courtroom the same levelof intellectual rigor that characterizes thepractice of an expert in the relevant field."Kumho Tire Co. v. Carmichael, 526 U.S.137, 152 (1999). Further, by the time thatyou prepare a Daubert motion, you shouldhave already established through depositions that the experts' opinions are nothingmore than subjective beliefs unsupportedby facts. Johnson, 685 F.3d at 452.What Happened, Why, and How?These questions are critical in every case. Asthe trial lawyer, you must frame them for ajury, and then answer them.through youropening, witness testimony, and closing.The same holds true for Daubert motions .With crowded dockets and motion calendars in every federal and state courthouse,judges, and their law clerks, do not haveFor The Defense December 2014 7511
TRUCKING LAWthe time to devote countless hours sifting through your brief to understand whathappened and that it happened the way thatyour client says it did. Simplifying the collision to its essentials for a judge or a clerkto understand is essential to succeeding ona Daubert or state-equivalent expert challenge. Further, most judges are not familiarwith the physics of a motor vehicle collision With the help of yourexpert, you must explain toa court that the followinggaps exist in a plaintiff'sexpert's report and opinion,rendering them uselessfor a jury to consider theliability of the partiesunder Fed. R. Evid.702.or how the body reacts to the forces generated by such a collision. Distilling measurements, speed rates, coefficients of friction,skid marks, yaw marks, and other factorsso that a court can appreciate why a plaintiff's expert's methodology is flawed andshould be excluded is no easy task.When moving to exclude an accidentreconstructionist's report and opinion, thefundamental argument that your expertcan assist you with is that the plaintiff'saccident reconstructionist did not adequately recreate the accident. From thisbasic premise, your client can prove thatthe adversary expert's methodology isunreliable. With the help of your expert,you must explain to a court that the following gaps exist in a plaintiff's expert's reportand opinion, rendering them useless for ajury to consider the liability of the partiesunder Fed. R. Evid.702.First, often, a plaintiff's experts neglect,sometimes purposefully, to calculate thepre-impact speed of the plaintiff's vehicle, assuming that the speed of that vehicle76 For The Defense December 2014is not relevant to why and how a collisionoccurred. Any good accident reconstructionist will calculate the speeds of all vehicles involved in a collision, or the walkingspeed of a pedestrian, if the case involvesa walking scenario, to determine whenthe vehicles arrived at the point of impactand who arrived first. A defense accidentreconstructionist can assist you to craft anargument that this gap in the report is nota credibility issue for a jury to consider,but rather a significant defect in the plaintiff's expert's methodology. Stated anotherway, both vehicles' speeds are necessary todetermine when each vehicle arrived at theimpact zone and in which order.Second, your accident reconstructionexpert can help you argue that a plaintiff's expert did not perform any calculations or that his or her calculations are notscientifically based, meaning that the evidence does not support them and physicsthat explain how the collision occurred. Wehad a case in which the plaintiff's accidentreconstructionist did just that, failed to calculate what the plaintiff's vehicle's speedwas when it entered the highway at the topof an on ramp and immediately in front ofour driver. Though the case settled soonafter we filed our Daubert brief, our accident reconstructionist helped us craft anargument that the plaintiff's retired-policeofficer turned-accident reconstructionistneeded to evaluate this critical element ofthe accident to determine who was at faultbut failed to do so.Third, in many tractor-trailer collisioncases, perception and reaction time arecritical crash factors that experts considerto determine which driver caused or contributed to a collision. A plaintiff's expertcannot or should not be allowed to avoidcalculating your driver's perception andreaction time. To opine that your driveris at fault, an expert must calculate thesetimes to demonstrate to a jury that yourdriver had more than enough time underthe circumstances to observe the plaintiff's vehicle, react to its presence, andavoid the collision. Your accident reconstructionist can help you to persuade acourt that a plaintiff's expert's methodology is flawed if he or she does not calculate pre-impact speed, time, and distanceelements-the distance of a tractor trailerfrom the impact site at which point thedriver should have seen the plaintiff's car,the distance that the truck traveled fromthis point, the plaintiff's pre-impact speed,the distance that the truck traveled fromthe time that the plaintiff saw your client'svehicle, and the time that it took the plaintiff to travel this distance. Your expert canclarify the specific data that a plaintiff'sexpert should rely on to establish a causalconnection between your driver and a collision and how the plaintiff's expert failedto do that.Finally, your biomechanical expert canalso assist you to argue that a plaintiff'sexpert is not a biomechanical engineer.This technical field requires an engineerto testify how the application of forces tothe human body resulted in the injuriessustained. An accident reconstructionistshould not be allowed to masquerade as abiomechanical engineer because the lattermust be trained in anatomy, physiology,medicine, body systems, and mechanicalengineering. Further, your expert can helpyou highlight the gaps in the methodologyused by a plaintiff's expert."Pay No Attention to that ManBehind the Curtain."This quote, from the pivotal scene in theclassic film, The Wizard of Oz, when Totopulls back the curtain to expose the greatand powerful "Oz" as an ordinary manoperating a smoke-and-mirrors illusion, .applies to many accident reconstructionand biomechanical experts. Too manyexperts will use legerdemain and misdirection to support theories that a drivernegligently operated a vehicle and causedan accident. Your experts can reveal irrelevant facts and data used by a plaintiff'sexpert to help support your argumentthat the expert's methodology is considered as unreliable under Daubert or doesnot prove causation for summary judgment purposes.Almost every trucking case now contains some allegation of driver fatigue,FMCSR violations, hours of service issues,cell phone use, texting while driving, andother examples of distracted driving. Thistype of evidence is certainly attractive toa court to justify denying a Daubert challenge because the evidence raises potentialfact questions that a jury should decide.However, the evidence must be relevant
under Fed. R. Evid. 401 and tend to provethat a driver caused a collision before itshould be admitted. For example, youraccident reconstructionist can demonstrate, using the physical evidence collectedfrom a crash scene and testimony from eyewitnesses, whether or not a collision waslikely caused by a distracted or fatigueddriver. With this information, you canargue in your brief that a plaintiff's expert'smethodology and conclusions are flawedbecause alleged past FMCSR violations,even log book deficiencies, are irrelevant towhether your driver carelessly drove his orher vehicle when he or she collided with theplaintiff's vehicle and the evidence does notexist to support that conclusion.Further, a plaintiff's accident reconstructionist, as the most likely type ofexpert to opine on fatigue and distracteddriving issues, more likely than not will nothave the expertise to testify on these topics. Too often we receive an accident reconstruction expert report from a plaintiff thatcontains everything plus the kitchen sinkon why our driver caused the accident.For instance, we once received a SO-page,single-spaced report. Your accident reconstructionist can help you divide a plaintiff'sexpert's opinions into those that purportto recreate the collision, those that actually do based on the facts gathered during the expert's investigation, and thosethat are beyond the expert's qualifications,such as opinions on log book violations orthat the driver drove distractedly. Similarly, your expert can assist you with investigating the numerous associations andreconstruction societies to which a plaintiff's accident reconstructionist typicallybelongs to show that his or her membershipin these groups or having attended a seminar does not mean that the expert has thequalifications to recreate an accident, opineabout log book violations, cell phone use,texting, fatigue, or other distracted driving indicators.Connecting the DotsEach state has its own standards for qualifying experts to testify at trial. However,no federal or state court allows an expert totestify based on "possibilities" or "subjective beliefs" on how an accident occurredor how a plaintiff sustained his or her injuries. Defense experts can help you explainto a court the gaps that exist in a plaintiff'sexpert's analysis between the facts and dataand the plaintiff's expert's conclusions.For example, an accident reconstructionistcannot testify that if your driver had sloweddown as he or she approached a crash site,the plaintiff would have been able to mergeonto the roadway without incident, or if thedriver had slowed down, the plaintiff wouldhave been able to clear the impact zone,unless the plaintiff's expert has calculatedvehicle speeds and perception and reactiontime, measured sight distances, and photographed sight lines. Your biomechanicalexpert can help you to argue that the mechanism for injury relied upon by a plaintiff'sexpert is not based upon facts in the case,
a biomechanical engineer's analysis and opinion on how injuries occurred is invalu able. Similar to an accident reconstruction ist, a biomechanical engineer can help the defense of a case in so many different ways. Deposition Preparation Your accident reconstruction
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