Life Care Planning Expert’s Testimony on Future Medical Care Needs Admitted

A July 2022 vehicle collision in Gallup, New Mexico, triggered a lawsuit claiming severe injuries. Plaintiff Jimmy Woodall claimed that Defendant
Curt Moeller made an “unsafe lane change,” forcing his tractor-trailer into a guardrail.

Woodall alleged that the crash caused him “severe and disabling injuries.” Woodall sued the Defendants, demanding  medical expenses along with damages for physical and mental pain and suffering, physical impairment, loss of enjoyment of life, and lost wages. 

To support his claim for these future medical care needs as related to the injury that he sustained, Woodall hired life care planner Todd Capielano. Capielano relied on the opinions of Woodall’s treating physicians to form his own assessment of the costs Woodall was likely to face. However, Defendants filed a motion under Daubert, challenging Capielano’s qualifications, reasoning, and methodology, as well as his reliance on the opinions of Woodall’s treating physicians.

Life Care Planning Expert Witness

Todd Capielano has a bachelor’s degree in rehabilitation counseling, which he obtained from Louisiana State University Medical Center, School of Allied Health Professions. He also has a master’s degree in human services counseling from the University of New Orleans.
In 2015, Capielano obtained a certification for life care planning from the University of Florida.

Discover more cases with Todd Capielano as an expert witness by ordering his comprehensive Expert Witness Profile report. 

Discussions by The Court

A. Qualifications

Defendants contended that Capielano relied on the opinions of Woodall’s treating physicians to fill in the gaps in his expertise. Because Capielano is not a physician and is not qualified to diagnose Woodall’s conditions, the Defendants argued that he cannot form a life care plan. 

However, the Court held that a life care planner’s reliance on the medical reports of other experts, even when the life planner does not have the same medical qualifications, does not make the life care planner unqualified.

Given that Defendants raised no other challenges to Capielano’s qualifications as a life care planner, the Court finds him qualified to testify as an expert regarding Woodall’s future medical expenses.

B. Reasoning and Methodology

Because Woodall’s treating physicians couldn’t quantify the extent of the aggravation to Woodall’s preexisting injuries, Defendants argued that Capielano’s life plan must be questionable. Additionally, they argued that this flaw in the life care plan “would mislead the jury and prejudice Defendants.” 

According to the Defendants, the life care plan incorrectly includes all of Woodall’s future medical expenses, while they should only be liable for the portion caused by the vehicle collision.

However, Woodall responded that the alleged shortcomings in the underlying medical opinions used to create the life care plan are properly addressed on cross-examination, not by excluding the life care plan entirely. The Court agreed.

Given that the jury already will be tasked with determining the extent to which Defendants’ conduct exacerbated Plaintiff’s condition, the Court added that it will not unfairly prejudice the Defendants or mislead the jury to have the jury conduct the same inquiry with regard to what portion of future expenses is attributable to Defendants’ conduct.

Held

The Court denied Defendants’ motion to exclude the opinions of Plaintiff’s expert Todd Capielano.

Key Takeaways:

• Defendants made no argument that Capielano’s qualifications are insufficient within the field of life care planning; rather, they appeared to argue that life care planning performed by a non-physician cannot support expert designation as a categorical matter.

• The trial will almost certainly involve discussions and inquiries about the preexisting injuries Woodall had and the extent to which they may have been aggravated by the collision in question. That is, the jury will determine the extent to which Woodall’s injuries and present condition are attributable to Defendants’ conduct, if any.

Case Details:

Case Caption:	Woodall v. W. Express, Inc.
Doket Number:	1:23cv862
Court:	United States District Court for the District of New Mexico
Order Date:	April 24, 2025