Rena Brenman and Mitchell D. Brenman, Plaintiffs-Respondents v. Michael Demello and Stephanie Demello…

Summary

The Supreme Court of New Jersey held that expert testimony is not a condition precedent to the admission of photographs of vehicle damage when the cause or extent of a plaintiff's injuries is at issue. The Court reversed the Appellate Division and reinstated the Law Division judgment, emphasizing that admissibility depends on relevance, proper authentication, and trial‑court discretion, not on a per‑se expert foundation. A dissent argued that expert proof is required for causation inferences, while a concurrence agreed with the result but cautioned against a rigid "certainty of proportion" rule.