Family Medicine Expert’s Testimony on Medical Facts in the Abstract Admitted 

In this personal injury case, Johnathan Mudge sought to recover for injuries allegedly resulting from an automotive collision that occurred on October 5, 2021.

Mudge has sued three Defendants in this matter: Riverside Transportation, Inc., Riverside Transport, Inc., and Rena Talton, the driver of the vehicle that collided with Plaintiff’s vehicle.

Defendants collectively filed a motion to exclude testimony from one of Plaintiff’s treating physicians, Dr. Winston B. Morris, a family medicine practitioner.

Plaintiff elicited testimony from him regarding the anatomy of the spine, including the grouping of vertebrae, the nature and function of spinal discs, and the nature, causes, and symptoms of spinal disc injuries.

Family Medicine Expert Witness

Winston Barrington Morris, MD, holds a Bachelor of Arts degree in Biology from the University of South Florida, and he graduated as a Doctor of Medicine from the Medical University of South Carolina in 1997. He completed family medicine residencies in 2004, and he is certified by the American Board of Family Practice.

Want to know more about the challenges Winston B. Morris has faced? Get the full details with our Challenge Study report.

Discussion by the Court

Morris offered some testimony based on scientific, technical, and otherwise specialized knowledge. For such testimony to be admissible in Court proceedings, Morris must be “qualified as an expert by knowledge, skill, experience, training, or education.” Morris’ medical education and significant experience as a doctor of family medicine satisfy this requirement.

Next, the Court must determine whether it is “more likely than not that the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue.” Morris’ medical knowledge is more likely than not to assist the jury in this case with understanding medical evidence and deciding on relevant medical facts. Thus, his testimony satisfies this requirement as well.

Finally, the opinions he offers in this case must be “based on sufficient facts or data; be the product of reliable principles and methods; and must reflect a reliable application of the principles and methods to the facts of the case.” The Court ruled that Morris’ testimony about general medical facts meets the required standard. His knowledge of how the brain, spine, and nervous system work comes from his medical training. While he may not be a specialist, it’s up to the jury to decide how much weight to give his testimony.

Similarly, Morris’ testimony regarding Plaintiff’s medical condition is based on his own experience treating the Plaintiff, including his review of Plaintiff’s own statements and medical records, in keeping with Morris’ medical training. The Court deemed it sufficient for his testimony to be admissible.

Held

The Court denied the Defendants’ motion to strike the testimony of Plaintiff’s treating physician, Winston Barrington Morris.

Key Takeaway:

Plaintiff has shown that Morris is qualified as an expert, and that it is more likely than not his specialized knowledge will assist the factfinder. He has also shown that Morris’ opinions are based on sufficient data, are the product of reliable principles and methods, and reflect a reliable application of the principles and methods. 

Case Details:

Case Caption:	Mudge V. Riverside Transportation Inc. Et Al
Docket Number:	2:23cv159
Court Name:	United States District Court, Texas Northern
Order Date:	August 04, 2025