Sheppard v. Geneva Rock, 493 P.3d 632

Background

In July 2012 Carol Sheppard's car was struck by a Geneva Rock truck driven by David Dalby; the defendants admitted liability shortly before trial.
The district court precluded all evidence of defendant negligence and negligent employment, so trial proceeded solely on damages.
Sheppard testified about immediate and continuing back pain and produced medical bills, including ~$65,000 billed by a physical therapist in Virginia.
She called Dr. Erekson, a physical-therapy expert, who testified that $28,685 of the bills were justified.
The jury awarded $30,000 in general damages, but the district court granted Geneva Rock's renewed motion for judgment as a matter of law, vacating the verdict and ruling Sheppard failed to meet the PIP statutory thresholds and lacked evidence of special damages.
The Utah Supreme Court reversed: (1) Sheppard could present special damages (causation fell within the common-knowledge exception and Dr. Erekson addressed necessity/reasonableness); (2) she met the PIP $3,000 medical-expense threshold for general damages; and (3) the court erred in categorically excluding evidence of Geneva Rock's negligent hiring/supervision after its admission of vicarious liability.

Issues

Issue	Plaintiff's Argument (Sheppard)	Defendant's Argument (Geneva Rock)	Held
1) Was JMOL proper on special (economic) damages?	Causation for continued treatment is within common knowledge; expert testimony not required for causation; Dr. Erekson addressed necessity/reasonableness.	Causation and necessity of later/complex treatments require expert proof; no adequate causal proof presented.	Reversed: causation could be submitted to jury under the common-knowledge exception and Dr. Erekson supplied sufficient expert support on necessity/reasonableness to avoid JMOL.
2) Did Sheppard meet the PIP statute threshold to seek general (noneconomic) damages?	Her recoverable medical expenses exceeded $3,000 as shown by Dr. Erekson's $28,685 opinion.	Medical-expense proof was insufficient without medical records or clearer causation.	Reversed: sufficient evidence existed to meet the PIP $3,000 medical-expense threshold, so general damages could be considered.
3) Was evidence of Geneva Rock's negligent hiring/supervision admissible after the employer admitted liability?	Evidence is relevant to damages (mental anguish/anxiety) and fault allocation; Jones v. Carvell does not bar such evidence when offered for damages or allocation.	Once liability is admitted, evidence going only to liability is irrelevant in absence of punitive damages.	Reversed: district court misapplied Jones; negligent-employment evidence may be relevant to damages and to fault allocation and thus should not have been categorically excluded.

Key Cases Cited

Bowman v. Kalm, 179 P.3d 754 (Utah 2008) (recognizes a limited common-knowledge exception that can excuse expert causation testimony).
Gorostieta v. Parkinson, 17 P.3d 1110 (Utah 2000) (plaintiff must show medical expenses reflect necessary treatment and are reasonable).
Jones v. Carvell, 641 P.2d 105 (Utah 1982) (evidence going only to liability is generally inadmissible when liability is admitted, absent punitive damages).
Beard v. K-Mart Corp., 12 P.3d 1015 (Utah Ct. App. 2000) (distinguishable court-of-appeals decision on need for expert proof of causal link for later surgeries).
Pinney v. Carrera, 469 P.3d 970 (Utah 2020) (distinguishes general and special damages; describes general damages as noneconomic pain-and-suffering).
Judd v. Drezga, 103 P.3d 135 (Utah 2004) (jury's role in assessing diminished enjoyment of life and mental reactions to physical injury).