Barnes v. Hodys
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This case arises from an automobile accident involving Lauren Barnes and Nancy Hodys, where both parties sustained serious injuries and neither has any memory of the accident. A syringe was found in Barnes' car and her urine later tested positive for opioids and benzodiazepines. Barnes filed a complaint against Hodys alleging her negligence caused the collision, while Hodys filed a complaint against Barnes alleging her negligence and intoxication caused the accident.
Barnes engaged Dr. David M. Benjamin as an expert witness, who concluded that it was "not possible to determine" whether Barnes' post-accident impairment was caused by head trauma, controlled substances, or medication. However, during deposition, Dr. Benjamin changed his previous opinion, stating that a combination of drugs and brain injury was the most likely explanation for Barnes' impairment. After the deposition, Barnes' counsel learned that Dr. Benjamin had a type of cancer, which along with the medication he was taking, caused him confusion, memory issues, and fatigue. Barnes then filed a motion to replace Dr. Benjamin due to his medical unavailability, which was denied by the lower court.
The Supreme Court of Rhode Island found that the trial court erred by not providing a rationale for its decision denying Barnes' motion to modify the scheduling order and replace her expert witness. The Supreme Court held that a reasoned exercise of discretion requires some explanation, which was not provided in this case. Therefore, the court quashed the order of the lower court and remanded the case back to that tribunal with instructions to conduct a meaningful analysis of the issues raised, consistent with the Supreme Court's opinion.
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