Car crashes that involve more than two vehicles can be hard to untangle. Who hit whom first, and in what order, often decides who is responsible — and by how much. When the physical evidence is unclear, both sides frequently hire accident-reconstruction experts who reach opposite conclusions.
That raises a basic question about how trials work: when two qualified experts disagree about how a collision happened, who gets to decide which one is right? Is it the judge, or the jury?
A recent decision from Florida’s Second District Court of Appeal addressed exactly that situation in a multivehicle rear-end case. In Angel v. White, the court explained what a trial judge may and may not do when the experts point in different directions.
Key Takeaway
When two experts give conflicting accounts of how a crash happened, a Florida trial judge generally cannot pick the winner and take the case away from the jury. Weighing that conflicting evidence is the jury’s job.
What happened in this case?
The plaintiff said he was stopped at a red light in his truck when he was rear-ended, feeling two impacts. Three drivers were involved, and the central dispute was the sequence of the collisions.
Each side called a forensic engineer who had reconstructed the accident. One expert opined that one driver’s vehicle hit the plaintiff’s truck first while stopped, and was then struck from behind, pushing it into the truck again. The other expert opined that a different driver struck the middle vehicle and propelled it into the truck, and that a competing version of events was inconsistent with physics.
Why did the trial court take the case from the jury?
After the jury deadlocked, the trial court declared a mistrial and granted a directed verdict in favor of the middle driver, assigning all liability to the rear driver. The judge reasoned that one driver’s account was physically impossible and found no evidence of negligence as to the middle driver.
The court also relied on Florida’s rebuttable presumption of negligence that attaches to a rear driver in a rear-end collision, concluding that the rear driver’s testimony was not enough to overcome it.
What did the appellate court decide?
The Second District reversed and sent the case back for a new trial. It reviews directed-verdict rulings without deference to the trial court, applying the same standard the trial judge should have used.
Under that standard, a directed verdict is proper only when no view of the evidence — and no reasonable inference from it — could support a verdict for the other side. The court must view the testimony in the light most favorable to the party opposing the motion. Where there are conflicts in the evidence or competing reasonable inferences, the issue is factual and belongs to the jury.
The court also emphasized that directed verdicts in negligence cases should rarely be granted, and are especially disfavored where comparative negligence — dividing fault among parties — is at stake.
Weighing evidence is the jury’s role
The appellate court explained that evaluating and weighing all the evidence, including competing expert testimony, is uniquely the jury’s function. Arguing that one side’s expert made the other version “impossible” is not, by itself, a legally sufficient basis to take the decision away from the jury.
What about the rear-end presumption and “stacking inferences”?
Florida recognizes a rebuttable presumption of negligence against the rear driver, but the court held it was not a proper basis to assign zero liability to the middle driver here, because one expert testified that the middle driver was actually the rear driver in the first impact with the truck. When a defendant offers evidence fairly tending to show the presumed facts are different, the whole matter goes to the fact-finder.
The court also rejected the argument that accepting one expert’s account required improperly “stacking” one inference on another. It noted that an expert’s testimony to the existence of a fact — even when contradicted — counts as direct evidence, not an inference drawn from circumstantial evidence.
Why does this matter to people involved in crashes?
This decision illustrates a general principle about how disputed accident cases are supposed to be resolved. When the facts genuinely conflict — including when experts disagree about the physics of a collision — the resolution typically rests with the jury rather than being decided as a matter of law by the judge.
It also shows that the rear-end presumption is not automatic in a chain of collisions; the specific sequence of impacts and who was where can keep the question of fault open for the jury.
Disclaimer: This post is for general information only, is not legal advice, does not create an attorney-client relationship, and does not predict or guarantee any result. The hiring of a lawyer is an important decision that should not be based solely upon advertisements. Before deciding, ask for free written information about the lawyer’s qualifications and experience.