In Dicosola v. Bowman, the First District tackled this issue: "Whether the trial court erred when it granted plaintiff's motions in limine to exclude photographs depicting the apparent minimal damage to plaintiff's postcollision vehicle and prohibiting defendant from arguing, without expert testimony, that a correlation existed between the amount of damage to the vehicle and the extent of plaintiff's injuries."
The Court decided that such an argument was impermissible and affirmed the trial court's decision to exclude the photos. "[A]bsent expert testimony, the evidence was inadmissible to show that a correlation existed between the amount of damage to plaintiff's vehicle and the extent of plaintiff's injuries"--
[W]conclude that the trial court did not abuse its discretion in granting plaintiff's motions in limine to (1) exclude evidence as to the dollar amount of property damage to plaintiff's or defendant's vehicle and (2) exclude testimony or photographs regarding the damage to the vehicles.
The Dicosola case also has a discussion of the now-rejected "same part of the body" rule, and reviews the trial court's decision to grant a motion for directed verdict against the defendant on liability.
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