Maldonado v. Flannery
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In this personal injury action, the Supreme Court reversed the judgment of the appellate court reversing the judgment of the trial court granting the joint motion for additurs filed by Plaintiffs and awarding each plaintiff additional money for pain and damages, holding that the trial court did not abuse its discretion by granting Plaintiffs' joint motion for additurs.
Plaintiffs, William Maldonado and Geovanni Hernandez, filed a negligence action against Defendants after a car accident. The jury returned a verdict in favor of Plaintiffs and awarded economic damages in the amount of $17,228 to Maldonado and $11,864 to Hernandez but declined to award noneconomic damages. The trial court granted Plaintiffs' motion for additurs, concluding that the jury verdict was inherently inconsistent and awarding past economic damages in the amount of $8000 to Maldonado and $6500 to Hernandez. The Supreme Court reversed, holding (1) the trial court's explanation of the basis for the additur award was sufficient; and (2) the trial court did not abuse its discretion by granting Plaintiffs' joint motion for additurs.
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