--- title: "Transportation Safety Expert Not Allowed to Opine on the Non-Preventability of the Crash" meta: "og:description": "The transportation safety expert shall not testify that the accident qualifies as a non-preventable crash under the CPDP" "og:title": "Transportation Safety Expert Not Allowed to Opine on the Non-Preventability of the Crash" author: "Shuva Guha Thakurta" description: "The transportation safety expert shall not testify that the accident qualifies as a non-preventable crash under the CPDP" --- # Transportation Safety Expert Not Allowed to Opine on the Non-Preventability of the Crash Posted on July 28, 2026 by Shuva Guha Thakurta This litigation arises from a motor vehicle accident that occurred during the early morning hours of May 10, 2023, on Interstate 20 in Bienville Parish, Louisiana. Ja'Vel Coleman alleged that she sustained injuries when her vehicle struck the rear of a tractor-trailer operated by Saint Fleur. According to Defendants, Saint Fleur experienced mechanical issues with his tractor-trailer and pulled onto the shoulder of Interstate 20 prior to the collision. Defendants retained [Keith Wilson](https://expertwitnessprofiler.com/expert-witness/Keith-Wilson/1577950) as an expert in the areas of commercial trucking operations, motor carrier safety practices, and Federal Motor Carrier Safety Administration ("FMCSA") regulations. Wilson issued opinions regarding Tara National's safety management practices, Saint Fleur's conduct leading up to the accident, and the applicability of certain FMCSA regulations. Coleman argued that Wilson's testimony should be excluded because: (1) he has never been qualified as an expert witness in any court; (2) he lacked the academic foundation necessary to provide opinions about motor carrier safety management, regulations, and driver conduct; (3) his opinion regarding the absence of FMCSA violations was formed without reviewing any documentation; (4) his opinion regarding the non-preventability of the crash has no bearing on civil liability; and (5) his opinion that the FMCSA regulations apply to Tara National is an undisputed fact not requiring expert testimony. ![Transportation Safety Expert Not Allowed to Opine on the Non-Preventability of the Crash](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_28T202402_4131.webp) ## **Transportation Safety Expert Witness** [Keith Wilson](https://expertwitnessprofiler.com/expert-witness/Keith-Wilson/1577950) has****experience as a commercial truck driver, an operations manager and compliance officer, and a director of safety. Wilson has experience overseeing compliance with FMCSA regulations, reviewing driver qualifications and developing driver safety programs, investigating accidents, and maintaining FMCSA-required records. He also holds certification as a Director of Safety through the North American Transportation Management Institute. [Discover more cases with Keith Wilson as an expert witness by ordering his comprehensive Expert Witness Profile report](https://expertwitnessprofiler.com/order/add?eId=1577950&pId=3). ## **Discussion by the Court** ### a. Qualifications The Court first addresses whether Wilson is qualified to offer expert testimony concerning motor carrier safety practices and FMCSA regulations. Coleman argued that Wilson lacked formal academic training in transportation safety and has not previously testified as an expert witness. The Court found that Wilson's substantial practical experience in commercial trucking operations and safety compliance provides sufficient specialized knowledge to assist the jury regarding trucking-industry practices and the application of FMCSA regulations. Accordingly, Wilson is qualified to offer expert opinions within those areas. ### b. Opinions Regarding Tara National's Safety Management Practices Coleman argued that Wilson's opinions regarding the adequacy of Tara National's safety management controls should be excluded because they were formed without reliable methodology and without reviewing the necessary documentation. Wilson reviewed FMCSA records, including information available through the SAFER database, and relied upon those records in forming his opinions. To the extent Wilson intends to testify regarding Tara National's regulatory status, the absence of reported FMCSA violations, the meaning of an "unrated" carrier designation, or the information reflected in the records he reviewed, such testimony is sufficiently supported by the materials he considered and may assist the jury in understanding the applicable regulatory framework. However, the Court found that Wilson's opinions must remain within the bounds of the information he actually reviewed. Wilson did not review the categories of safety-management records that would permit him to assess the adequacy of Tara National's internal safety practices. Accordingly, while Wilson may testify regarding Tara National's regulatory status and the absence of reported FMCSA violations, he may not extrapolate from those facts to offer broader opinions that Tara National's safety management controls were adequate. The Court found that the compliance review resulting in a "conditional" rating may be explored through cross-examination. The existence of the later review does not render Wilson's methodology inadmissible, but it does show why Wilson's testimony should be confined to the regulatory information he actually reviewed rather than broader conclusions about the adequacy of Tara National's internal safety-management practices. ### c. Opinions Regarding Reasonableness of Saint Fleur's Conduct Coleman next argued that Wilson's opinion that Saint Fleur's conduct was reasonable should be excluded because it was based solely on Saint Fleur's self-serving deposition testimony. Wilson's report reflects that he reviewed materials beyond Saint Fleur's deposition testimony, including the Louisiana Uniform Motor Vehicle Crash Report, body-camera footage, witness testimony, and other discovery materials. While Coleman disputes the conclusions Wilson drew from those materials, such disagreement does not establish that Wilson employed an unreliable methodology. To the extent Coleman contended that Saint Fleur's account is inaccurate or self-serving, those arguments are properly directed to the weight of Wilson's opinions rather than their admissibility. The credibility of Saint Fleur's testimony is a matter for the jury. However, Wilson may not offer testimony that suggests to the jury that they should find Saint Fleur credible or instructs them on how disputed factual issues should be resolved. Similarly, Wilson may not offer legal conclusions that Saint Fleur was "not negligent" or otherwise satisfied the applicable legal standard of care. Accordingly, subject to the limitations outlined above, the Court declined to exclude Wilson's opinions concerning Saint Fleur's conduct. ### d. Opinions Regarding Non-Preventability Classification Next, Coleman argued that Wilson's opinion regarding the non-preventability of the crash has no bearing on civil liability and should therefore be excluded. The FMCSA Crash Preventability Determination Program ("CPDP") is an administrative program utilized by the FMCSA for regulatory and safety-rating purposes. Whether an accident may qualify for consideration under that program does not determine whether a party acted negligently under Louisiana law or whether any alleged negligence caused Coleman's injuries. Thus, introduction of the fact that the crash was determined as non-preventable under the CPDP is irrelevant to the issues before the jury and risks confusing the applicable legal standard. Accordingly, the Court found that any limited probative value associated with such testimony is substantially outweighed by the risk of juror confusion. Wilson shall not testify that the accident qualifies as a non-preventable crash under the CPDP, nor shall he offer opinions concerning how the FMCSA might classify the accident for administrative purposes. ### e. Opinions on Applicability of FMCSA Regulations Finally, Coleman argued that Wilson's opinion that the FMCSA regulations apply to Tara National should be excluded because it is an undisputed fact not requiring expert testimony. Wilson was retained to provide opinions concerning commercial trucking operations, motor carrier safety practices, and compliance with FMCSA regulations. To the extent Wilson intends to explain the purpose of FMCSA regulations within the commercial trucking industry, such testimony may assist the jury in understanding the regulatory framework applicable to motor carriers and commercial drivers. Likewise, the Court held that Wilson may offer opinions regarding whether the conduct at issue was consistent with industry practices and the FMCSA regulations he reviewed. However, Wilson may not offer testimony that instructs the jury on the law or provides legal conclusions. ## **Held** The Court granted in part and denied in part Coleman's [_Daubert_](https://www.law.cornell.edu/wex/daubert_standard) motion to exclude the testimony of Keith Wilson. ## **Key Takeaway** - Wilson may testify regarding Tara National's absence of reported FMCSA violations, its "unrated" carrier designation, and the information reflected in the records he actually reviewed, but he may not offer broader opinions that Tara National maintained adequate safety management controls beyond what can be supported by those records; - Wilson may not offer testimony regarding the credibility of Saint Fleur or other witnesses, nor may he offer legal conclusions, including opinions regarding negligence, fault, or compliance with the applicable legal standard of care; - Wilson may not testify that the accident qualifies as a non-preventable crash under the FMCSA CPDP nor may he offer opinions concerning how the FMCSA might classify the accident for administrative purposes. ## **Case Details:** | Case Caption: | Coleman V. Navigators Insurance Co | | --- | --- | | Docket Number: | 5:24cv512 | | Court Name: | United States District Court, Louisiana Western | | Order Date: | July 13, 2026 | --- ## **You Might Also Like** ![Transportation Safety Expert Not Allowed to Opine on the Non-Preventability of the Crash](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_28T202402_4131.webp) [**Transportation Safety Expert Not Allowed to Opine on the Non-Preventability of the Crash**](https://expertwitnessprofiler.com/transportation-safety-expert-not-allowed-to-opine-on-the-non-preventability-of-the-crash/transportation-safety-expert-not-allowed-to-opine-on-the-non-preventability-of-the-crash)![Economics Expert Allowed to Opine on Toy Sales](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_28T170323_8161.webp) [**Economics Expert Allowed to Opine on Toy Sales**](https://expertwitnessprofiler.com/transportation-safety-expert-not-allowed-to-opine-on-the-non-preventability-of-the-crash/economics-expert-allowed-to-opine-on-toy-sales)![Mechanical Engineering Expert Allowed to Opine on Hail Impacts](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_28T175252_204.webp) [**Mechanical Engineering Expert Allowed to Opine on Hail Impacts**](https://expertwitnessprofiler.com/transportation-safety-expert-not-allowed-to-opine-on-the-non-preventability-of-the-crash/mechanical-engineering-expert-allowed-to-opine-on-hail-impacts)![Law And Legal Expert Was Allowed to Opine on Claims Handling Customs ](https://media.jurimatic.com/images/blog_pic_640X480_2026_07_28T175214_7561.webp) [**Law And Legal Expert Was Allowed to Opine on Claims Handling Customs **](https://expertwitnessprofiler.com/transportation-safety-expert-not-allowed-to-opine-on-the-non-preventability-of-the-crash/law-and-legal-expert-was-allowed-to-opine-on-claims-handling-customs-)![Psychology Expert's Testimony About PICS Limited](https://media.jurimatic.com/images/blog_pic_640X4801.webp) [**Psychology Expert's Testimony About PICS Limited**](https://expertwitnessprofiler.com/transportation-safety-expert-not-allowed-to-opine-on-the-non-preventability-of-the-crash/psychology-experts-testimony-about-pics-limited)