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Morris v Doolittle; (COA-UNP, 10/5/1994; RB #1737)


Michigan Court of Appeals; Docket No. 157156; Unpublished  
Judges Corrigan, Connor, and Power; Unanimous; Per Curiam  
Official Michigan Reporter Citation:  Not Applicable; Link to Opinion alt   

Serious Impairment of Body Function Definition (Difranco Era – 1987-1995) [§3135(1)]  
Objective Manifestation Element of Serious Impairment (Difranco Era – 1987-1995) [§3135(1)]  
Liability for Excess Economic Loss Caused by Insured Tortfeasors [§3135(3)(b)]  
Causation Issues [§3135]

Not Applicable    

In this unanimous per curiam unpublished Opinion, the Court of Appeals affirmed directed verdict in favor of the defendant on the issue of causation, based upon plaintiffs failure to produce competent evidence of either a herniated disc or an aggravation of a pre-existing condition.  

Plaintiff was involved in a motor vehicle accident in 1984, and commenced action in 1987, alleging that the accident had caused her to suffer a herniated disc in her neck. Plaintiff had a history of prior traffic and pedestrian accidents involving a variety of injuries. Although one of plaintiff s physicians testified that the motor vehicle accident caused plaintiffs neck injuries, the trial court determined that this witness lacked the necessary foundation for his opinion of causation because he was not familiar with specific characteristics of the accident that occurred. In affirming the trial court, the Court of Appeals held that the plaintiff’s proofs on the issue of causation did not rise above "mere conjecture" and that plaintiff had failed to establish that the accident at issue caused her neck injury or aggravated a pre-existing condition. In so ruling, the Court of Appeals held that plaintiff had failed to introduce evidence establishing a physical basis for any subjective complaints of pain and suffering. The Court of Appeals also rejected plaintiffs argument for wage loss damages. While it is not required to show a serious impairment of body function for excess wage loss damages, the court held that plaintiff had failed to show that the accident at issue caused the injuries from which she claimed her damages flowed.

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