Albert David Matthew, M.D. v. Unum Life Insurance Company, No. 10-2514 (8th Cir. 2011)
Annotate this CasePlaintiff, a urologic surgeon of 18 years, sued defendant seeking disability benefits under the terms of his disability insurance policy with defendant after he developed a degenerative ankle condition which prevented him from doing surgical procedures that required standing for more than an hour and a half. At issue was whether the district court erred in granting plaintiff's post-trial motion to correct the special verdict; in awarding prejudgment interest; and in denying defendant's post-trial motions for judgment as a matter of law, a new trial, and declaration of mistrial. The court held that the district court did not clearly abuse its discretion where its finding was supported by the jury's response to Question Six on the special verdict form and in amending the judgment, the district court was merely correcting a mistake that appeared on the face of the verdict; the district court erred in awarding prejudgment interest under Minnesota common law where it would be inequitable to award prejudgment interest when plaintiff prevented defendant from determining the amount of its potential liability by failing to provide the relevant financial information; the district court properly concluded that plaintiff's residual disability claim was not barred by the statute of limitations; the court need not decide whether the district court erred in submitting the residual disability benefits issue to the jury because defendant was estopped from making that argument under the invited error doctrine; and the district court did not err in denying defendant's motion for a mistrial based on a post-trial communication from a member of the jury concerning deliberations.
Court Description: Civil case - Insurance. District court did not clearly abuse its discretion in amending the judgment to correct a mistake that appeared on the verdict form; district court erred in awarding prejudgment interest under Minnesota common law as the plaintiff's damages had not been readily ascertainable; district court did not err in finding plaintiff's residual disability claim was not barred by the statue of limitations; under the invited error doctrine, the defendant was estopped from arguing the court erred in submitting the residual benefits issue to the jury; district court did not err in denying defendant's motion for a mistrial based on a post-trial communication from a member of the jury concerning deliberations; case remanded with instructions to determine whether prejudgment interest is available to plaintiff under Minn. Stat. Sec. 549.09.
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