Jlg Trucking, Llc v. Lauren R. Garza, 466 S.W.3d 157

July 16, 2008: Garza was rear‑ended by a JLG Trucking employee; she sought treatment and later physical therapy for neck/back pain.
October 9, 2008: Garza was in a second collision; transported to hospital on a backboard with a cervical collar and complained of neck pain; MRI soon thereafter showed cervical herniations.
Garza sued JLG for negligence arising from the July collision and called her treating surgeon, Dr. Pechero, to testify that the July crash caused her herniated discs and resulting damages; JLG retained a neuroradiologist, Dr. Berberian, who opined degeneration, not trauma.
JLG sought to introduce evidence of the October crash as an alternative cause; Garza moved pretrial to exclude all evidence of the second accident as irrelevant and prejudicial; the trial court granted the motion and excluded that evidence.
The jury returned a large verdict for Garza; the court of appeals affirmed the exclusion, reasoning expert proof was required to link the second collision to the injuries.
The Texas Supreme Court reversed: evidence of the second accident was relevant to causation and exclusion was harmful, particularly because it prevented probing Dr. Pechero’s basis for ruling out the October collision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of evidence of the second (October) accident	Garza: second accident is not causally connected to her injuries and including it would confuse/jurors and be unfairly prejudicial	JLG: evidence of the second accident is relevant as an alternative plausible cause of the injuries and necessary to challenge causation	Court: Evidence of the second accident was relevant under Tex. R. Evid. 401; exclusion was an abuse of discretion
Whether expert proof was required to make the second accident relevant	Garza: absent expert linking the October accident to the herniations, the evidence is inadmissible	JLG: expert testimony is not required for relevance; factual records and temporal proximity make the October crash a plausible alternative cause	Court: The court of appeals conflated relevance with sufficiency; lack of an expert for defendant goes to weight, not relevance; exclusion improperly shifted plaintiff’s burden

Interstate Northborough P’ship v. State, 66 S.W.3d 213 (Tex. 2001) (standard of review for exclusion of evidence: abuse of discretion)
Guevara v. Ferrer, 247 S.W.3d 662 (Tex. 2007) (expert testimony required to prove medical causation beyond jurors’ common knowledge; relevance distinct from legal sufficiency)
Burroughs Wellcome Co. v. Crye, 907 S.W.2d 497 (Tex. 1995) (causation requires proof that defendant’s conduct caused an event which caused compensable injury)
Transcontinental Ins. Co. v. Crump, 330 S.W.3d 211 (Tex. 2010) (plaintiff must exclude other plausible causes with reasonable certainty when expert proof is required)
Reliance Steel & Aluminum Co. v. Sevcik, 267 S.W.3d 867 (Tex. 2008) (harmless‑error framework for evidentiary rulings; consider whether excluded evidence was crucial to key issue)
E.I. du Pont de Nemours & Co. v. Robinson, 923 S.W.2d 549 (Tex. 1995) (expert must consider and rule out alternative causes when proving medical causation)
Farmers Tex. Cnty. Mut. Ins. Co. v. Pagan, 453 S.W.3d 454 (Tex. App.—Houston [14th Dist.] 2014) (distinguishable—court excluded alternative‑cause evidence where record lacked factual support linking the incident to the injuries)