Dana Companies v. Crawford

Summary

The Delaware Supreme Court reviewed post-trial motions arising from an asbestos-related mesothelioma case involving Dana Companies and Zoom Performance Products. The court affirmed the defendants’ judgment on liability, but held that the trial court improperly evaluated separate damages awards collectively when denying additur. It reversed in part and remanded for reconsideration of the pain-and-suffering award and for determination of whether Louisiana law permits a deceased plaintiff to recover wrongful-death damages.

Holdings

1. A trial court may not evaluate the adequacy of a damages award for one claim by considering the jury's award on a separate claim. Each claim must be evaluated solely on the evidence bearing on that claim, consistently with the jury instruction requiring separate consideration of each claim.
2. The case must be remanded for the Superior Court to reconsider whether additur is warranted for Elizabeth Henderson's pain-and-suffering award, evaluating that award solely in light of the evidence supporting that claim and without reference to awards on separate claims.
3. The Superior Court was required to determine whether Louisiana law permits a deceased plaintiff to be awarded damages in a wrongful-death action and, if so, to reconsider the plaintiffs' motion for additur concerning Bruce Henderson's $0 loss-of-consortium award.
4. The Superior Court's judgment denying Dana's and Zoom's post-trial motions was affirmed.

Questions Presented

1. Whether the Superior Court properly denied the plaintiffs' motion for additur or a new trial concerning the $80,000 award for Elizabeth Henderson's pain and suffering.
2. Whether the adequacy of damages for separate claims may be evaluated by considering the awards for other claims that would benefit the same beneficiaries.
3. Whether Louisiana law permits a deceased plaintiff to receive damages for loss of consortium or other damages in a wrongful-death action when the plaintiff died before trial.
4. Whether the Superior Court properly denied the defendants' post-trial motions for judgment as a matter of law or a new trial.

Disposition

reversed_and_remanded