Injured in a Crash With a City Truck? A Missouri Appeal Offers a Useful Reminder

A new Missouri Court of Appeals decision involving a City of St. Louis garbage truck shows how courts handle comparative fault, preexisting injuries, and medical causation evidence.

City vehicle cases often raise the same question injured drivers ask after any serious crash: if the government vehicle caused the collision, can the injured person still recover in a meaningful way? In Marks v. City of St. Louis, No. ED113479 (Mo. Ct. App. E.D. Mar. 3, 2026), the Missouri Court of Appeals answered that question in a very practical setting involving a garbage truck, a disputed knee injury, and a jury verdict against the City.

The opinion is useful because it is not built around abstract immunity issues or unusual procedural twists. At its core, it is a motor vehicle injury case about fault, causation, and how much evidence a plaintiff needs to get medical testimony in front of a jury.

What Happened in the Crash

According to the opinion, Terence Marks was involved in a motor vehicle collision with a City of St. Louis garbage truck on February 14, 2023. Marks sued the City for negligence. The case went to trial, and in December 2024 a jury returned a verdict in his favor.

The jury assessed 90 percent fault to the City and 10 percent fault to Marks. It awarded total damages of $288,000, which resulted in a judgment for Marks of $252,000 after the reduction for comparative fault.

The City’s Main Argument on Appeal

The City challenged several trial rulings, but one of its central arguments focused on medical causation. Marks had treated with Dr. Nathan Mall, who testified that Marks’ right-knee symptoms were attributable to the collision. The City argued that testimony should not have been admitted because Marks had a preexisting knee condition and, in the City’s view, the doctor’s opinion rested too heavily on Marks’ own history.

The Court of Appeals rejected that argument. The court noted that Dr. Mall saw Marks within days of the crash, took a history, performed an examination, reviewed imaging, and ordered treatment. The court also pointed out that while Marks had a prior meniscus injury and surgery years earlier, there was evidence he had not needed treatment for the knee since that recovery and that his post-crash symptoms were consistent with what he reported to the doctor.

Why the Court Affirmed the Verdict

The Eastern District held that the City’s objections to Dr. Mall’s testimony went to weight, not admissibility. In other words, the City was free to argue that the jury should not believe the doctor’s conclusions, but that did not mean the jury should never hear them in the first place.

The court also rejected the City’s complaints about closing argument, the denial of a mistrial request, and the refusal to submit a mitigation instruction. The end result was simple: the judgment for Marks was affirmed.

Why This Case Matters for Injury Claims

This case is relatable because it reflects issues that come up all the time in personal injury litigation. Defendants often argue that a plaintiff’s pain came from a preexisting condition rather than the crash. Plaintiffs, on the other hand, often need to show that an older condition had become manageable or asymptomatic before the new collision changed things.

Marks reinforces that a prior injury does not automatically defeat a present claim. If the treating doctor has a reliable basis for linking current symptoms to the accident, that testimony may properly go to the jury even when the defense sees the medical history differently.

Takeaway

Marks v. City of St. Louis is a useful Missouri appellate decision for anyone following crash litigation, comparative fault, or injury claims involving preexisting medical conditions. It shows that a city vehicle case can still turn on the same core issues seen in many other negligence cases: who was at fault, what the crash caused, and whether the defense’s attacks on medical evidence are strong enough to keep the case from the jury.

Tom Henderson
Tom Henderson
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