Willie B. Southern, Jr. v. Nathaniel Younger, et al.

This case arises from a motor vehicle collision involving a governmental entity, resulting in chronic spinal injury, long-term functional impairment, and a subsequent federal disability determination of total disability. In the state proceedings, the trial court reduced damages and rejected much of the medical and functional limitation evidence, while the appellate courts affirmed without addressing (i) functional limitations documented by treating providers, (ii) federal disability statutes applicable to governmental defendants, or (iii) the probative value of a post-judgment federal disability determination. The questions presented are:

1. Medical-Causation & Federal Disability Intersection Whether a state court may discount or disregard medically supported functional limitations and disability findings connected to a tort-based physical injury—while simultaneously affirming reduced damages— without violating federal disability statutes, including the Americans with Disabilities Act (42 U.S.C. § 12101 et seq.) and Section 504 of the Rehabilitation Act (29 U.S.C. § 794), and without conflicting with this Court’s decisions recognizing the legal relevance of federal disability determinations and functional limitation evidence.

2. Administrative Disability Determinations as Competent Evidence Whether a state court’s refusal to consider or give weight to Social Security Administration disability determinations, corroborated by medical records, functional capacity evidence, and treating-provider records, raises a substantial federal question concerning the status and evidentiary relevance of federal administrative disability findings in civil litigation, in conflict with this Court’s guidance in Cleveland v. Policy Mgmt. Sys. Corp., 526 U.S. 795 (1999), and related disability jurisprudence.

3. Procedural Fairness & Fourteenth Amendment Due Process Whether affirming materially reduced damages in the presence of extensive unrefuted medical, functional-limitation, and administrative disability evidence—while precluding meaningful evidentiary development regarding impairment and limitations—violates the Fourteenth Amendment’s procedural fairness guarantees by denying a full and fair opportunity to be heard on issues central to causation and damages. LIST OF PARTIES