Federal District Court Held that Alcohol Consumption Evidence Was Highly Probative for Determining Plaintiff’s Life Expectancy and Damages and Was Admissible Evidence for that Limited Purpose

The plaintiff moved to preclude any introduction of his history of alcohol consumption as irrelevant and prejudicial. The defendant contended the plaintiff’s consumption was relevant to his projected life expectancy and it also provided an explanation for a subsequent fall unrelated to the plaintiff’s claimed physical limitations. 

In deciding the plaintiff’s motion, the federal district court noted, “[e]vidence about alcohol must be approached with great care.” The district court found the plaintiff’s alcohol consumption was not an isolated occurrence but, instead, was a recurrent issue that existed for years and was documented by his doctors in medical records. The court held that information of the plaintiff’s alcohol consumption was highly probative of the plaintiff’s long-term health care costs and life expectancy. 

The court noted, while the plaintiff produced a life care plan report to establish damages, the report failed to account for how the plaintiff’s alcohol use may impact his life expectancy. The court ruled, since “life expectancy is the single most critical determinant of the estimated damages,” factors that impact it are highly relevant under the Rules of Evidence. The court held the prejudicial impact of the evidence of alcohol consumption does not substantially outweigh the highly probative value it has on the plaintiff’s life expectancy and damages. 

The federal court ruled that the evidence may be introduced for determining life expectancy but was inadmissible for any other purpose. 

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