Haddigan v. Harkins
1970 U.S. App. LEXIS 6279, 441 F.2d 844 (1970)
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Rule of Law:
In a federal diversity case governed by Pennsylvania substantive law, a plaintiff seeking future damages must present actuarial evidence or other mathematical guidance to the jury for the purpose of reducing future losses to their present worth. The failure to provide such guidance is reversible error.
Facts:
- Thomas W. Haddigan was driving south on a four-lane divided highway with his wife, Margaret Haddigan, as a passenger.
- Haddigan lost control of his vehicle, which swerved across the road and came to rest on the concrete median divider, protruding into the northbound lanes.
- Cornelius J. Harkins was driving north in the left northbound lane, and William T. Baker was driving north in the right northbound lane.
- There was testimony that the Haddigan car was stalled on the divider for approximately half a minute while Harkins and Baker were approaching from 100-150 yards away.
- A three-car collision occurred involving the vehicles driven by Haddigan, Harkins, and Baker.
- Margaret Haddigan was ejected from her vehicle during the collision.
- Baker admitted that his car ran over Margaret Haddigan after she was ejected.
- Margaret Haddigan died from her injuries less than two hours after the accident.
Procedural Posture:
- Margaret Haddigan's administrator filed a diversity suit in the U.S. District Court against drivers Cornelius J. Harkins and William T. Baker, asserting claims under Pennsylvania's Wrongful Death and Survival Acts.
- Harkins, Baker, and Thomas W. Haddigan (the decedent's husband and driver) all filed cross-claims and third-party claims against each other for contribution and personal injuries.
- Following a ten-day trial, a jury returned a verdict on special interrogatories, finding all three drivers negligent.
- The jury awarded the administrator $64,754.30 on the wrongful death claim and $7,500 on the survival claim, for which Harkins and Baker were liable.
- The district court entered judgment on the verdict.
- All parties except the plaintiff administrator filed post-trial motions for a new trial or judgment notwithstanding the verdict, which the district court denied.
- All unsuccessful parties appealed the district court's judgment to the U.S. Court of Appeals for the Third Circuit.
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Issue:
Does federal procedural law require the presentation of actuarial evidence and mathematical guidance for a jury to calculate the present worth of future damages in a diversity case, even if the governing state substantive law only permits, but does not mandate, such evidence?
Opinions:
Majority - Gibbons, J.
Yes. Federal courts require that juries be provided with evidence and appropriate mathematical guidance to rationally calculate the present worth of future damages, and this procedural requirement applies in diversity cases even where state law does not mandate it. The court found that the jury's verdict on liability, holding all three drivers negligent, was supported by the evidence. However, the damages award must be reversed for two reasons: the trial court gave the jury an incorrect life expectancy figure for the decedent, and the plaintiff failed to provide any actuarial evidence or expert guidance to help the jury reduce future damages to present worth. While Pennsylvania law makes such evidence permissive, the federal court, following the precedent set in Russell v. City of Wildwood, holds that such guidance is mandatory in federal court to prevent jury verdicts based on 'mere conjecture or guess.' The court affirmed the trial court's ruling that evidence of a surviving spouse's remarriage is inadmissible under Pennsylvania law.
Dissenting - Aldisert, J.
No. Federal courts in diversity cases should not impose a mandatory evidentiary rule for proving damages when the governing state law makes such evidence merely permissive. The majority's decision creates a federal procedural rule that alters the substantive requirements of proof under Pennsylvania law without any 'affirmative countervailing considerations' as required by Byrd v. Blue Ridge. This ruling conflicts with prior Third Circuit precedent (Tabor v. Miller) which held that mortality tables are not required to prove life expectancy under Pennsylvania law. By making actuarial evidence mandatory, the court is improperly overriding state law and creating an inconsistency within its own jurisprudence that warrants a rehearing.
Analysis:
This case establishes a significant procedural rule for federal diversity cases within the Third Circuit, highlighting a key issue under the Erie doctrine. By mandating actuarial evidence for present worth calculations even when state law does not, the court prioritizes the federal interest in ensuring rational, non-speculative jury verdicts over strict adherence to state evidentiary practices. This decision increases the burden and cost on plaintiffs bringing diversity claims in federal court, as they must now retain experts for damages calculations. It creates a notable divergence between the procedural requirements in federal versus state court for the same underlying cause of action.
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