Voykin v. Estate of DeBoer

This appeal presents the question of whether a defendant must present medical or other competent evidence of a causal or relevancy connection between a plaintiff’s prior injury, prior accident, or preexisting condition and the injury at issue.

BACKGROUND

This action arose from an automobile accident between plaintiff, Mark Voykin, and decedent, Gordon DeBoer. The evidence at trial established that, on January 31, 1996, decedent’s car collided with the rear of plaintiffs car. Although plaintiff did not seek medical attention on the evening of the accident, the next morning, at his wife’s…