This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A catastrophic automobile accident occurred in 1993 near Las Vegas, New Mexico, involving a 1984 Plymouth Laser manufactured by the Defendant. The Plaintiff, who was intoxicated and speeding, swerved to avoid an oncoming vehicle, causing the car to crash and catch fire. Two passengers in the back seat died in the fire, while the Plaintiff suffered burns and psychological injuries, including post-traumatic stress disorder (paras 2-4).
Procedural History
- District Court of San Miguel County: The jury awarded the Plaintiff $1,000,000 in compensatory damages, reduced to $700,000 under comparative fault principles. The Defendant's motion for remittitur or a new trial was denied, despite the trial judge finding the award excessive and shocking to the conscience (paras 5-7).
Parties' Submissions
- Appellant (Defendant): Argued that the $1,000,000 jury award was excessive, as the Plaintiff incurred only $5,000 in economic damages, with the remainder based on pain and suffering. The Defendant contended that the verdict shocked the conscience and should be reduced (para 6).
- Appellee (Plaintiff): [Not applicable or not found]
Legal Issues
- Whether the trial court abused its discretion by denying the Defendant's motion for remittitur or a new trial after finding the jury's award of damages excessive and shocking to the conscience.
Disposition
- The Court of Appeals reversed the trial court's decision and remanded the case for further consideration (para 18).
Reasons
Per Bosson J. (Alarid and Wechsler JJ. concurring):
The trial judge erred by failing to exercise discretion after finding the jury's award excessive and shocking to the conscience. The judge's refusal to act, citing a lack of legal guidelines for assessing pain and suffering, constituted reversible error (paras 11-12). The appellate court emphasized that trial judges are uniquely positioned to evaluate jury awards due to their direct observation of the trial and their role as the first safeguard against excessive verdicts (paras 13-14). The court declined to establish specific guidelines for pain and suffering, reaffirming that such determinations rest on the trial judge's judgment and the facts of each case (paras 13, 16). The case was remanded for the trial judge to decide whether to order remittitur or a new trial, ensuring the Plaintiff retains the option to choose between the two (paras 18-19).