Miller v. Huron Regional Medical Center, No. 18-1522 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of HRMC's motion for remittitur or a new trial following the jury's award of damages to plaintiff, one of HRMC's former physicians, in a breach of contract action. The court held that the jury's award was not so grossly excessive that the district court committed a manifest abuse of discretion in failing to order remittitur for a lesser amount; even if HRMC's analysis of the Health Care Quality Improvement Act of 1986 immunity provision was correct, HRMC failed to properly preserve the issue; and there was no injustice in this case where HRMC had ample opportunity to raise this defense but failed to do so until it was too late.
Court Description: Kelly, Author, with Loken and Erickson, Circuit Judges] Civil case - Breach of contract. The district court did not err in denying defendant's motion for remittitur or a new trial; the jury award on plaintiff's breach of contract award was not so grossly excessive that it shocked the judicial conscience; defendant did not preserve its issue that the damages award violated the immunity provisions of the Health Care Quality Improvement Act of 1986 as it did not raise the issue in a Rule 50(a)motion prior to submission of the case to the jury; there is no injustice in the court's decision not to review the claim as defendant had ample opportunity to raise the defense and did not do so until it was too late.
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