Badahman v. Catering St. Louis

Summary

The Missouri Supreme Court affirmed an order granting a new trial on compensatory damages after the circuit court found the jury’s award inadequate and against the weight of the evidence. The court held that Missouri’s conditional additur procedure under section 537.068 and Rule 78 does not violate the constitutional right to a jury trial when the opposing party may reject the additur and elect a new jury trial. The court also held that the trial court did not abuse its discretion by limiting the new trial to compensatory damages.

Holdings

1. Section 537.068 and Rule 78.10 do not violate the Missouri constitutional right to a jury trial because the defendant may reject the additur and obtain a new jury trial on damages; accepting the additur constitutes a waiver of the jury-trial right.
2. When a circuit court sustains a motion for additur or, alternatively, a new trial and the defendant elects a new trial, the order is reviewed under the same standard applicable to a new trial granted because the verdict is against the weight of the evidence: the evidence is viewed in the light most favorable to the circuit court's order, and the ruling is reviewed for manifest abuse of discretion.
3. The circuit court did not abuse its discretion in finding the $11,250 compensatory-damages verdict inadequate and against the weight of the evidence and in ordering a new trial.
4. The circuit court did not abuse its discretion by ordering a new trial limited to compensatory damages because Catering St. Louis did not show that liability and compensatory damages were substantially intertwined or that a damages-only trial would cause injustice.

Questions Presented

1. Whether Missouri Revised Statutes section 537.068 and Rule 78.10 violate the Missouri constitutional right to a jury trial by permitting conditional additur.
2. What standard of appellate review applies when a circuit court sustains a motion for additur or, alternatively, a new trial because the verdict is against the weight of the evidence.
3. Whether the circuit court abused its discretion by finding the compensatory-damages verdict inadequate and ordering a new trial.
4. Whether the circuit court abused its discretion by limiting the new trial to compensatory damages.

Disposition

affirmed