Serious impairment claim dismissed for lack of objective manifestation
Kristi Schmidt sued David Gwizdala after he caused a 2004 collision that injured Schmidt's back and neck. She claimed that the collision aggravated injuries she suffered in a 2002 collision and constituted a "serious impairment" of an important body function that affected her general ability to lead her normal life. [That is the threshold a Michigan resident must meet to sue a drunk or negligent motorist]. Schmidt claimed that in combined effect, the two collisions caused her doctor to restrict her from a planned career in early childhood development. The trial court dismissed her claim, finding that she had not adequately alleged either an objective manifestation or a serious impairment. Her appeal was dismissed because she did not offer appellate argument to address the lower court's ruling on objective manifestation of her injuries.