Akins Funeral Home, Inc. v. Miller

Summary

The Alabama Supreme Court reviewed consolidated appeals arising from the mistaken cremation of Matthew Miller's body by funeral homes. The court considered the admissibility of expert testimony concerning post-traumatic stress disorder, the excessiveness of compensatory damages, and the excessiveness of punitive damages. It affirmed the judgments for Andrea Megan Miller and Teresa Miller against Akins Funeral Home, Inc.

Holdings

1. The trial court did not abuse its discretion by permitting Davidson to testify as an expert regarding the plaintiffs' grief-related trauma and post-traumatic stress disorder.
2. The compensatory-damages awards were not excessive, and the trial court properly declined to reduce them.
3. The punitive-damages awards of $150,000 to each plaintiff were not excessive.

Questions Presented

1. Whether the trial court abused its discretion by allowing Judy Davidson, who was not a physician, psychiatrist, psychologist, or licensed counselor, to testify as an expert concerning the plaintiffs' psychological trauma and post-traumatic stress disorder.
2. Whether the compensatory-damages awards of $450,000 to Andrea Megan Miller and $200,000 to Teresa Miller were excessive.
3. Whether the punitive-damages awards of $150,000 to each plaintiff were excessive.

Disposition

affirmed