William L. Roach v. Transwaste, Inc.

Summary

The Connecticut Supreme Court affirmed the Appellate Court’s decision upholding a jury award of $24,288 in lost wages in the plaintiff’s wrongful-termination action against Transwaste, Inc. The court held that damages may be proved with reasonable certainty through uncorroborated testimonial evidence when that evidence enables a reasonable, nonspeculative estimate. The jury’s calculation, based on the plaintiff’s testimony regarding mileage, compensation, and unemployment duration, was sufficiently supported by the evidence.

Holdings

1. Lost wages are proved with reasonable certainty when the evidence is sufficient to enable the fact finder to make a fair and reasonable estimate and thereby remove the award from speculation; testimonial evidence alone may satisfy that standard if the jury’s reliance on it is reasonable.
2. The award was not impermissibly speculative because it was based on uncontroverted testimony and a calculation method disclosed in the jury interrogatories, including a reasonable estimate of mileage and unemployment duration.
3. The Appellate Court correctly upheld the trial court’s denial of Transwaste’s motion for remittitur.

Questions Presented

1. Whether the evidence was sufficient to establish Roach’s lost wages with reasonable certainty.
2. Whether the trial court abused its discretion by denying Transwaste’s motion for remittitur.

Disposition

affirmed