## Facts

- Joseph Wiltz was rear-ended by Maya Welch in a low-speed automobile collision in Louisiana.
- Wiltz sued Welch and Welch’s insurer, State Farm Mutual Automobile Insurance Company, seeking damages for past and future medical expenses, lost wages, pain and suffering, and loss of enjoyment of life.
- Liability for the collision was not the main dispute at trial; the focus was whether Wiltz suffered compensable injury and what damages, if any, were caused by the accident.
- Wiltz sought medical evaluation and treatment after the collision, but the evidence did not establish that he was diagnosed with an objective injury caused by the accident.
- At trial, evidence showed Wiltz had been involved in numerous prior accidents and had preexisting conditions and complaints similar to those he attributed to this crash.
- Wiltz failed to disclose his prior accidents and injuries to treating physicians evaluating him after this collision.
- Wiltz’s discovery responses concerning his prior accident and injury history were found to be dishonest and evasive, allowing the defense to challenge his credibility and the claimed causal link between the crash and his complaints.
- The jury awarded Wiltz compensatory damages for past medical expenses only and awarded $0 for general damages (pain and suffering) and $0 for other claimed special damages (lost income and future medical expenses).
- Wiltz moved for a new trial (and related relief), arguing the verdict was inconsistent under Louisiana law because medical expenses were awarded without general damages.
- The district court denied the motion, finding the record permitted a reasonable jury to award medical expenses yet conclude Wiltz failed to prove compensable pain and suffering from this accident.

## Issues

1. Under Louisiana law, was the jury’s award of past medical expenses but no general damages for pain and suffering (and no other special damages) legally inconsistent on this record?
2. Did the district court abuse its discretion in denying Wiltz’s motion for a new trial based on the asserted inconsistency and weight of the evidence?

## Decision

- The Fifth Circuit affirmed the judgment and affirmed the district court’s denial of a new trial.
- The court held the verdict was not invalid as a matter of Louisiana law because the evidence supported a finding that Wiltz did not prove objective, accident-caused injury and that much of his post-accident care was evaluative or precautionary.
- The court held the district court acted within its discretion in leaving the jury’s damages determination intact given the evidentiary basis and the jury’s role in assessing credibility and causation.

## Legal Principles

- In diversity cases, federal law supplies the standard for ruling on and reviewing a motion for new trial (abuse of discretion), while state law governs the substantive rules on recoverable damages.
- Louisiana law does not impose a categorical rule that an award of medical expenses must be accompanied by an award of general damages; the validity of such a verdict depends on the trial record.
- A useful dividing line in Louisiana cases is whether the plaintiff proved objective injuries that required medical care as a result of the accident; when objective injury is proven, denying general damages may be an abuse of discretion, but when objective injury is not proven and care is primarily evaluative, awarding medical expenses alone can be reasonable.
- A jury may award limited past medical expenses for evaluation after a minor collision yet reject claims for pain and suffering, wage loss, and future care when the plaintiff fails to prove that the accident caused a compensable injury.
- Credibility problems—such as nondisclosure of prior accidents and injuries to treating physicians and dishonest or evasive discovery responses—can support a finding that subjective complaints are unreliable and that causation is not established.
- Appellate courts give substantial deference to jury damage awards and to the trial court’s denial of a new trial when the verdict has a reasonable evidentiary basis.

## Conclusion

Wiltz v. Welch upheld a split verdict awarding only past medical expenses after a low-speed rear-end collision because the jury could reasonably find that Wiltz failed to prove an objective injury caused by the accident and that his medical care was largely evaluative, especially in light of extensive preexisting conditions and credibility problems stemming from nondisclosures and misleading discovery; therefore, the Fifth Circuit affirmed the denial of a new trial.


Wiltz v. Welch, 651 F. App'x 270 (2016)