This conclusion accords with human experience, our prior cases, and the law in other states where courts have held that causation as to certain types of pain, bone fractures, and similar basic conditions following an automobile collision can be within the common experience of lay jurors. See Burandt v. Clarke, 274 Or. 521, 547 P.2d 89 (1976) ("As defendants concede, medical testimony of causation between collision and injury is not essential if there is an `uncomplicated situation.'"); see also Choi v. Anvil, 32 P.3d 1, 4 (Alaska 2001); Roling v. Daily, 596 N.W.2d 72, 75 (Iowa 1999); Walton v. Gallbraith, 15 Mich.App. 490, 166 N.W.2d 605, 606 (1969). Thus, non-expert evidence alone is sufficient to support a finding of causation in limited circumstances where both the occurrence and conditions complained of are such that the general experience and common sense of laypersons are sufficient to evaluate the conditions and whether they were probably caused by the occurrence.

Medical testimony is not necessary to establish a causal link between a violent automobile collision and soreness and pain which begin immediately following the accident. Burandt v. Clarke, 274 Or. 521, 547 P.2d 89 (1976). What Is The Consequence of Absence of Medical Testimony to Support The Award for Loss of Enjoyment of Life?

Because the causation and injuries were reasonably related to the impact between the automobiles, there was no need for an expert.See, e.g., Roling v. Daily, 596 N.W.2d 72, 74-75 (Iowa 1999); Walton v. Gallbraith, 166 N.W.2d 605, 606 (Mich.App. 1969); Burandt v. Clarke, 547 P.2d 89, 89-90 (Or. 1976). Choi's argument that the plaintiffs' actions in leaving the scene of the accident without seeking medical treatment were inconsistent with their claims of injury properly goes to the weight of the plaintiffs' testimony, not to its admissibility or its legal sufficiency.