Citation. State Farm Mut. Auto. Ins. Co. v. Campbell, 123 S. Ct. 1513, 538 U.S. 408, 155 L. Ed. 2d 585, 71 U.S.L.W. 4282, 60 Fed. R. Evid. Serv. (Callaghan) 1349, 1 A.L.R. Fed. 2d 739, CCH Prod. Liab. Rep. P16,805, 2003 Cal. Daily Op. Service 2948, 2003 Daily Journal DAR 3783, 16 Fla. L. Weekly Fed. S 216 (U.S. Apr. 7, 2003)
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Brief Fact Summary.
Plaintiff, a young child, was severely burned during a house fire caused by the Defendants’ negligent manufacture of a heater. The jury awarded plaintiff $2,000,000 in compensatory damages and the defendants moved for remittitur.
Synopsis of Rule of Law.
Under the maximum recovery rule, a court will overrule a jury’s determination of damages only if the damages exceed the maximum amount the jury could reasonably find based upon all of the evidence.
Facts.
The Plaintiff, Helen Britian (Plaintiff), was severely burned as a young child when her home was destroyed by a fire. The blaze was caused by a heater negligently manufactured by the Defendants, Sears and Controls Company of America (Defendants). The jury awarded plaintiff $2,000,000 in compensatory damages. Defendants moved for remittitur.
Issue.
Was the trial court correct in determining that the verdict of the jury did not exceed the maximum amount which the jury could reasonably find based on the maximum recovery rule?
Held.
Yes. Defendant’s motions for a remittitur are denied.
* The maximum recovery rule is intended to protect the role of the jury as finder of facts. Judges must determine only the maximum award that the jury could reasonably have reached, based on all of the evidence as to each element of damages.
* In the present case, five elements of damages are applicable: (i) past physical and mental pain; (ii) future physical and mental pain; (iii) future medical expenses; (iv) loss of earning capacity and permanent disability and (v) disfigurement. This Court examines each of these elements individually, determining the maximum amount of damages available under each based on the evidence available. Considering each of these elements in unison, this Court determines that the maximum jury award supported by the evidence is $2,980,000. Therefore, the jury’s damage award is valid.
* The Defendants also argue that the introduction of photographs of the Plaintiff was inflammatory and that the presence of the child in the courtroom inflamed or prejudiced the jury. The photographs were allowable because part of Plaintiff’s claim for damages was for disfigurement and humiliation. Also, the presence of Plaintiff was not inappropriate because Plaintiff was well behaved and quiet during all courtroom proceedings.
Discussion.
A motion for remittitur is a request for the court to lower the damages levied against a defendant. If granted, the plaintiff may generally either accept the remittitur or request a new trial.
