Jody R. Davis v. Jeffrey D. Mullen

Summary

The Supreme Court of Pennsylvania held that a jury's award of medical expenses without damages for pain and suffering is not necessarily inconsistent. The court affirmed the denial of a new trial because the trial court had a reasonable basis to conclude that the jury either did not believe Davis suffered compensable pain or attributed the alleged pain to a preexisting condition or another cause. The court rejected a per se rule requiring an award for pain and suffering whenever medical expenses are awarded.

Holdings

1. A jury's award of medical expenses without compensation for pain and suffering is not subject to a per se rule requiring a new trial. The verdict should not be disturbed when the trial court had a reasonable basis to believe either that the jury did not believe the plaintiff suffered pain and suffering or that a preexisting condition or injury was the sole cause of the alleged pain and suffering.
2. The trial court acted within its discretion in denying Davis's motion for a new trial because the evidence reasonably supported the jury's conclusion that Davis did not suffer compensable pain or that his alleged injury was not caused by Mullen's negligence.

Questions Presented

1. Whether a jury verdict awarding medical expenses but no damages for pain and suffering is necessarily inconsistent and requires a new trial.
2. Whether the trial court abused its discretion by denying Davis's motion for a new trial where the evidence provided a reasonable basis for the jury to disbelieve that Davis suffered compensable pain or that the accident caused his alleged injury.

Disposition

reversed