

Daryl Dixon · Alejandro Gonzales
Campbell Circuit Court, Kentucky | Case No. 24-CI-00099 Verdict: $332,000.00
CASE SUMMARY
Plaintiff: Jenny Garrard (Age 49 at collision) Defendants: Northern Kentucky Water District; Jonathan K. Daniels (employee/driver) Date of Incident: August 3, 2023
Theory: Negligence / Respondeat Superior
THE COLLISION
Jenny Garrard was stopped at a red light on US 27 in Cold Spring, Kentucky. Jonathan Daniels, driving a 2023 Kenworth T480 dump truck for the Water District, rear-ended her vehicle when the light turned green—mistakenly believing she had begun moving forward.
Key Admissions from Defendant Driver:
When asked what he could have done differently: "Focused more"
Could not recall distance behind plaintiff's vehicle or whether he was using his cell phone
Had not seen photographs of vehicle damage despite characterizing collision as a "bump"
Critical Procedural Development: Defense stipulated to duty and breach, conceding liability. Trial focused solely on causation and damages.
DIAGNOSED INJURIES
Cervical Spine
Disc herniations at C4-C7; ligament sprain; muscle strain; cervicogenic headaches
Lumbar Spine
L4-S1 disc herniation with stenosis, foraminal narrowing
Left Knee
Medial femoral condyle contusion; Grade 1-2 MCL sprain (resolved)
Neurological
Concussive syndrome.
DAMAGES
Past Medical Bills - $28,638.56
Future Medical Bills - $500,885.15
Past and Future Pain & Suffering - $3,000,000.00
TOTAL - $3,529,523.71
Verdict - $332,000.00
KEY TRIAL THEMES
Plaintiff:
"MRIs Don't Lie" – Objective imaging showed structural damage
"Forever Injury" – Permanent disc herniations requiring lifetime care
Admitted fault through stipulation
"Health is the most treasured gift we have"
Defense:
Pre-existing/degenerative conditions
Subjective complaints unsupported by objective findings
Excessive chiropractic treatment (100+ visits)
Minor "bump" collision
Plaintiff told defendant at scene she was not injured
LESSONS LEARNED
Jurors will accept Chiropractic Treatment but they need to see more Orthopedic Treatment.
Jurors will accept Chiropractic Treatment--- They would like to see mostly Orthopedic Treatment.
Objective Imaging is Critical – 3.0 Tesla MRI provided undeniable visual evidence of disc herniations that resonated with the jury.
Pre-Existing Conditions – Prior records are very important. Defense looks for every single word in every single record.
Life Care Planning – Comprehensive future care plan from qualified physiatrist provides concrete framework for future damages.
Verdict Analysis – $332,000. Some jurors were on the verge of 1-2 Million in Pain and Suffering. Several Male jurors were at zero. We wanted to strike those Male Jurors. Jury awarded half of the Chiropractic Treatment. Extensive chiropractic treatment may have concerned jurors.
CONCLUSION
This case illustrates the critical importance of Jury Selection, objective medical evidence, qualified expert witnesses, and proactive management of pre-existing conditions. While the verdict was significantly below the demand, it represented meaningful compensation and established defendant responsibility in a tough Conservative Jurisdiction. The stipulation to liability streamlined trial but can reduce the emotional weight of defendant's conduct.
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