Ryan v. Zurich American Ins. Co.

Summary

The Louisiana Supreme Court held that a jury's determination of the amount, if any, of damages for lost future earning capacity is a factual finding subject to manifest-error review. Because the jury's zero award was supported by a reasonable factual basis, the court of appeal erred by substituting its judgment and conducting a de novo review. The court reversed the increased award for lost earning capacity and reinstated the jury's zero award, while affirming the judgment in all other respects.

Holdings

1. A jury's determination of the amount, if any, of lost earning capacity is an issue of fact subject to the manifest error standard of review.
2. The jury's zero award was supported by a reasonable factual basis, and the court of appeal erred by substituting its own credibility determinations for those of the jury.

Questions Presented

1. Whether the jury's zero award for loss of future earning capacity was a factual determination subject to manifest-error review.
2. Whether the court of appeal properly conducted a de novo review and substituted its own judgment for the jury's determination.
3. Whether the jury's zero award was supported by a reasonable factual basis.

Disposition

other