Missouri Eastern District Split Over Evidence of Habitual Marijuana Use in Motor Vehicle Accidents

In a recent case before the Missouri Court of Appeals, Eastern District, Schultz v. Great Plains Trucking, Inc., No. ED111241, 2024 Mo. App. LEXIS 195 (App. E.D. Mar. 26, 2024), the court was divided over the admissibility of evidence regarding a mother’s alleged chronic marijuana use at the time of a motor vehicle crash that claimed her son’s life. Ultimately, the court upheld a verdict from the trial court that exceeded $10 million for Plaintiffs. While the mother was driving, she lost control of her vehicle in rainy conditions, leading to a collision with another car. Her vehicle was subsequently struck by an 18-wheeler truck owned by Defendant. The lawsuit, brought against the truck driver and his employer, resulted in a jury awarding compensatory and aggravating damages to Plaintiffs. Although other points on appeal were considered, the focal point of the Court’s opinion was whether expert opinion testimony regarding the mother’s allegedly chronic marijuana use should have been presented to the jury to demonstrate evidence of impairment at the time of the crash.

Judge Robert Clayton III, writing for the majority, upheld the trial judge’s decision to exclude evidence of the mother’s marijuana use as unreliable and irrelevant, emphasizing the lack of conclusive proof of impairment and the absence of Missouri legal precedent allowing evidence of impairment based solely on regular marijuana usage. However, Judge Cristian M. Stevens authored a dissenting opinion, contending that the mother’s habitual marijuana use was pertinent, especially given that recreational marijuana use is now a constitutional right in Missouri. Despite agreeing on the exclusion of blood THC levels due to scientific uncertainty, Judge Stevens argued that Schultz’s habitual use could have contributed to impairment, potentially altering the jury’s perspective. This case highlights the legal complexities surrounding recreational marijuana use in Missouri in the context of motor vehicle accidents and underscores the ongoing evolution of legal standards in response to changing societal attitudes and laws on the issue.