Daly v. McFarland
Annotate this CaseChristopher Daly sued Zachary McFarland for injuries sustained from an accident. The jury returned a special verdict form finding that both Daly and McFarland were negligent, but that Daly's negligence was not a direct cause of the accident. The jury then allocated thirty percent of the fault for the accident to Daly. The district court entered judgment for Daly in the amount of $442,633, the full amount of damages that the jury found Daly to have suffered. McFarland moved for judgment as a matter of law, arguing that the court improperly reconciled the jury's special verdict form answers, and that McFarland was not negligent as a matter of law. In the alternative, McFarland moved for a new trial. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the district court abused its discretion in reconciling the special verdict form; and (2) because the jury found McFarland to be at least seventy percent causally negligent for the accident, the case was remanded with directions to enter a remittitur awarding Daly $309,843, and if Daly rejected the remittitur, to grant a new trial on liability issues.
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