Gostyla v. Chambers, 176 Conn. App. 506

Plaintiff (Gostyla) sued defendant (Chambers) for personal injuries from a 2011 rear-end vehicle collision; defendant admitted negligence but disputed causation.
Defendant disclosed Calum McRae, a biomechanical engineer, as an expert; his videotaped deposition was played at trial because he was unavailable to testify live.
McRae opined he could quantify the forces (estimated max ~2.3 g) and generally what injuries such forces produce, but, over objection, stated the collision did not cause the plaintiff’s specific injuries.
Trial court denied the plaintiff’s motion in limine to exclude McRae’s causation opinion, ruling it was a biomechanical (not medical) opinion and admissible; the jury returned a verdict for the defendant.
On appeal the plaintiff argued McRae was not qualified to offer specific-causation opinions (a medical determination); the trial court’s admission of that testimony was erroneous.
Appellate court concluded the causation testimony was improperly admitted because it exceeded McRae’s biomechanical expertise, but affirmed the judgment because the plaintiff failed to provide an adequate trial record to show the error was harmful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a biomechanical engineer may testify that a specific collision did or did not cause a particular plaintiff’s injuries	McRae lacked medical training; thus his specific-causation opinion exceeded his expertise and should be excluded	McRae was qualified in biomechanics and could offer biomechanical causation opinions; cross-examination could expose limits	Abuse of discretion to admit: biomechanical experts may testify about forces and general injury mechanisms but not diagnose specific-causation absent medical qualifications
Whether admission of the improper testimony required a new trial	Admission was prejudicial and likely affected the verdict; new trial warranted	Any error was harmless or plaintiff failed to show prejudice on the record	No new trial: appellant failed to provide sufficient trial transcript/materials to show the erroneous admission likely affected the result

Weaver v. McKnight, 313 Conn. 393 (2014) (expert must be qualified and factual basis must support opinion; qualifications challenge often goes to weight)
Smelser v. Norfolk Southern Ry. Co., 105 F.3d 299 (6th Cir. 1997) (biomechanical engineers qualified to explain forces/general injury types but not specific medical causation)
Bowers v. Norfolk Southern Corp., 537 F. Supp. 2d 1343 (M.D. Ga. 2007) (distinguishing general causation testimony from impermissible specific-causation medical opinions)
Vitali v. Southern New England Ear, Nose, Throat & Facial Plastic Surgery Group, LLP, 153 Conn. App. 753 (2014) (standard of review and trial court discretion on expert admissibility)
Combs v. Norfolk & Western Ry. Co., 256 Va. 490 (1998) (biomechanical expert competent on forces but not on medical causation of particular injury)