Aundrey MEALS Ex Rel. William MEALS v. FORD MOTOR COMPANY
417 S.W.3d 414, 2013 WL 4673609, 2013 Tenn. LEXIS 702 (2013)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
When a trial court approves a jury's verdict in its capacity as the thirteenth juror, an appellate court's review is limited to determining whether there is any material evidence to support the award. If such evidence exists, the appellate court cannot disturb the verdict.
Facts:
- Six-year-old William 'Billy' Meals was a passenger in a 1995 Mercury Grand Marquis manufactured by Ford Motor Company.
- His father placed the shoulder strap of the three-point seatbelt behind Billy's back because it crossed his face, leaving him restrained solely by the lap belt.
- A vehicle driven by an intoxicated driver, John Harris, crossed the median and collided head-on with the Meals' vehicle.
- The collision killed Billy's father, grandfather, and John Harris, leaving Billy as the sole survivor.
- The force of the impact caused Billy to jackknife over the lap belt, which was pushed into his abdomen and against his spine.
- This action fractured Billy's lumbar spine, causing permanent paralysis from the waist down and severe internal injuries.
- Billy required numerous surgeries, including the removal of a significant portion of his small intestine, and faced lifelong medical issues, including lack of bowel and bladder control.
Procedural Posture:
- Aundrey Meals, on behalf of her son Billy, filed a product liability lawsuit against Ford Motor Company in the Circuit Court for Shelby County.
- A jury returned a verdict in favor of the Plaintiff, awarding $43.8 million in compensatory damages and allocating 15% of the fault to Ford.
- Ford filed a motion for a new trial, arguing the verdict was excessive, but did not specifically request a remittitur.
- The trial court denied the motion for a new trial and approved the jury's verdict in its capacity as thirteenth juror.
- Ford, as appellant, appealed to the Tennessee Court of Appeals, arguing the verdict was excessive.
- The Court of Appeals, in a divided opinion, agreed with Ford and suggested a remittitur, reducing the total award to $12.9 million.
- The Plaintiff, as appellant, was granted permission to appeal to the Supreme Court of Tennessee.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Did the Court of Appeals err by suggesting a remittitur of a jury's compensatory damages award when the trial judge had already approved the verdict as the thirteenth juror and material evidence in the record supported the award?
Opinions:
Majority - Sharon G. Lee, J.
Yes. The Court of Appeals erred because its authority to suggest a remittitur is highly circumscribed when the trial judge has already approved the verdict as the thirteenth juror. The appellate court's review is limited to determining whether any material evidence supports the verdict. Here, the evidence regarding the catastrophic, permanent, and life-altering nature of the child's injuries, his extensive pain and suffering, and his substantial economic losses constituted material evidence sufficient to support the jury's $43.8 million award. By substituting its own judgment for that of the jury and the trial judge, and by relying on an inapposite case for comparison, the Court of Appeals exceeded its deferential standard of review.
Analysis:
This decision reinforces the high degree of deference appellate courts must afford to jury verdicts that have been approved by a trial judge acting as the thirteenth juror. It solidifies the 'material evidence' standard as a significant barrier to appellate intervention in damage awards, thereby protecting the jury's constitutional role as the primary fact-finder. The ruling makes it more difficult for defendants to successfully challenge large, yet factually supported, jury awards on appeal in Tennessee, emphasizing that an appellate court cannot simply substitute its own view of what is 'reasonable' for that of the jury.
Unlock the full brief for Aundrey MEALS Ex Rel. William MEALS v. FORD MOTOR COMPANY