Saleh v. Ribeiro Trucking, LLC

Summary

The Connecticut Supreme Court held that the trial court abused its discretion in ordering a remittitur of a jury's noneconomic damages award in a motor vehicle negligence case. The court concluded that the evidence supported the jury's $687,868 noneconomic damages award and affirmed the Appellate Court's reversal of the remittitur. The court also required that future remittitur orders state clear, definite, and satisfactory reasons supporting the reduction.

Holdings

1. The trial court abused its discretion because, when the evidence was viewed in the light most favorable to sustaining the verdict, the jury's $687,868 noneconomic-damages award fell within the necessarily uncertain range of fair and reasonable compensation and was supported by the evidence.
2. In all future cases, a trial court ordering a remittitur must state in its memorandum of decision clear, definite, and satisfactory reasons for the order, including the evidence viewed in the light most favorable to sustaining the verdict and the specific reasons why the award shocks the court's sense of justice.
3. It is not inherently improper for a trial court to estimate reasonable damages for a period and multiply that amount by the duration of the recovery period, so long as the method does not violate the requirement that a supported jury award be sustained.

Questions Presented

1. Whether the Appellate Court properly concluded that the trial court abused its discretion in granting a remittitur and setting aside the jury's verdict.
2. What showing and explanation a trial court must provide when ordering a remittitur of a jury's damages award.

Disposition

affirmed