In Flores v. Gutierrez, 951 N.E.2d 632 (Ind. Ct. App. 2011), plaintiff sued defendant driver following a rear-end car collision occurring in Hammond, Indiana, and he obtained a default judgment on the issue of liability. Prior to the jury trial on damages, plaintiff filed a motion in limine seeking to exclude one of defendant’s exhibits which was a photograph of plaintiff’s car showing little to no damage to the vehicle. The trial court denied plaintiff’s motion and admitted the photograph at trial. On appeal, the Indiana Court of Appeals decided as a matter of first impression if the photograph displaying the property damage was properly admitted in this personal injury case. The Indiana Court of Appeals upheld the trial court’s ruling recognizing “the common sense relationship between property damage and personal injury” and holding the trial court was within its discretion to admit the photographs.