Delco v. Stafford

813 So. 2d 458, 2001 La.App. 1 Cir. 0018, 2002 La. App. LEXIS 236, 2002 WL 241131
CourtLouisiana Court of Appeal
DecidedFebruary 20, 2002
DocketNo. 2001 CA 0018
StatusPublished
Cited by3 cases

This text of 813 So. 2d 458 (Delco v. Stafford) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Delco v. Stafford, 813 So. 2d 458, 2001 La.App. 1 Cir. 0018, 2002 La. App. LEXIS 236, 2002 WL 241131 (La. Ct. App. 2002).

Opinions

CIACCIO, J. Pro Tem.

This appeal arises following a judgment notwithstanding the verdict increasing plaintiffs award for general damages and future lost wages.

FACTS

This litigation stems from a collision between two semi tractor trailer rigs on November 14, 1998 in Assumption Parish. As the rigs passed each other on the two-lane Louisiana Highway 662, defendant Eugene Stafford poached slightly into plaintiffs lane.

Plaintiff Joseph Lee Delco, Jr. filed suit against Mr. Stafford, his employer, Tycoon Trucking, Inc., and its insurer, Clarendon National Insurance Company, for injuries allegedly sustained in the accident. After a trial, a jury allocated 100 percent fault to defendant Stafford and awarded damages:

General damages $ 3,000.00
Past medical expenses 26,716.46
Future medical expenses 02
Past lost wages 40,000.00
Future lost wages 57,000.00

for a total of $126,716.46. Plaintiff subsequently moved for a judgment notwithstanding the verdict (JNOV), arguing that the damage awards were inadequate. The trial court granted the motion and increased plaintiffs general damage award to $125,000.00 and the award for future lost wages to $150,000.00.

Defendants now appeal, alleging that the trial court erred in granting plaintiffs JNOV by 1) weighing the evidence and evaluating witnesses’ credibility and 2) increasing damage awards that were logical and consistent with the evidence.

IsLAW AND ARGUMENT

LSA-C.C.P. art. 1811 is the authority for a JNOV. In Davis v. Wal-Mart Stores, Inc., 00-0445 (La.11/28/00), 774 So.2d 84, 89 the Louisiana Supreme Court discussed the standard to be used in determining whether a JNOV has been properly granted:

A JNOV is warranted when the facts and inferences point so strongly and overwhelmingly in favor of one party that the court believes that reasonable jurors could not arrive at a contrary verdict. The motion should be granted only when the evidence points so strongly in favor of the moving party that reasonable men could not reach different conclusions, not merely when there is a preponderance of evidence for the mover. If there is evidence opposed to the motion which is of such quality and weight that reasonable and fair-minded men in the exercise of impartial judgment might reach different conclusions, the motion should be denied. In making this determination, the court should not evaluate the credibility of the witnesses and all reasonable inferences or factual questions should be resolved in favor of the non-moving party. (Emphasis ours.)

In general, the standard of review for a JNOV is twofold. First, we must determine that the jury verdict was not supported by competent evidence and was wholly unreasonable. To make this determination, we must find that all of the evidence, when viewed in a light most favorable to the party benefiting from the JNOV, points so strongly and overwhelm[461]*461ingly in his favor that reasonable men could not arrive at a contrary verdict on the issue. Davis v. Wal-Mart Stores, Inc., 774 So.2d at 89. Only if we find that the trial judge properly granted the JNOV will we move forward to the second prong and review the JNOV using the manifest error standard. Id.

Plaintiff testified that only his knee hurt immediately after the accident, but later that night, he went to Terrebonne General Medical Center “[f|or back and neck injury.” Later, on cross examination, plaintiff testified, ‘‘Well, I told [hospital staff] my back and neck was (sic) bothering me, but mainly I had headaches.”

The police report and photographs supported plaintiffs testimony that defendant Stafford “came over into my lane and ran all the way down the side of my truck.” But Dr. William Kinnard testified that plaintiff sought treatment for injuries sustained in a “head-on” collision. At the time, plaintiff told him that the |4knee pain had subsided, but the pain in his back and neck continued. Plaintiff described neck pain and a tingling sensation in both arms, as well as lower back pain and burning in his thighs.

Dr. Kinnard testified that plaintiffs x-rays and neurological exams were normal, but he noted tenderness and spasms in the lower back. According to Dr. Kinnard, the patient cannot control whether and when the muscles will contract in a spasm. Thus, rather than a plaintiffs subjective reports of pain, the spasm served as objective evidence to substantiate his complaints.

Further testing showed a disc abnormality. Dr. Kinnard testified that after several months, conservative treatments had not helped and plaintiff felt that the pain was intolerable. Dr. Kinnard performed disc surgery in June, 1999. By August, the spasms had ceased and plaintiff was able to resume physical therapy. Dr. Kinnard testified that he anticipated releasing plaintiff one year after the surgery.

Plaintiff testified that he had absolutely never hurt his back before this accident. After some memory prodding on cross-examination, plaintiff remembered seeing a doctor for “a little strain, but it didn’t really bother me ...” after attempting to lift a large roll of film at work. Dr. Bruce Guidry testified that he treated plaintiff for a back strain after this incident. In addition, evidence showed that plaintiff filed a 1992 lawsuit alleging lower back strain as a result of an auto accident. Plaintiff testified that he sought treatment at Terrebonne General Hospital for neck and back injury, but that he was not really hurt. Dr. Kinnard testified that plaintiff never told him about any prior back injuries.

Trevor Bardarson, a physical therapist, testified that plaintiff claimed in his evaluation to be severely disabled and unable to return to work. Mr. Bardarson performed a functional capacity test, but deemed the test invalid because, in his opinion, plaintiff did not exert maximum effort. Mr. Bar-darson testified that when he pushed on plaintiffs lower back, his heart rate did not increase as it would for |fisomeone who was truly in pain. What’s more, according to Mr. Bardarson, plaintiffs complaints of pain in various places did not make sense anatomically.

Dr. Christopher Cenac evaluated plaintiff for the defense. Apparently, plaintiff also told Dr. Cenac that he was injured in a “head-on” collision. Dr. Cenac testified that he found no muscle spasm and therefore would not have recommended surgery. He found some evidence of wear and tear, but believed that plaintiff suffered from a pre-existing, work-related degenerative condition. Dr. Robert Guimlty [462]*462further testified that plaintiffs bulge was fairly common. Even Dr. Kinnard admitted on cross-examination that the lifting incident could have led to the disc bulge and that a significant percentage of the population has that type of wear and tear bulge by age forty.

Plaintiff testified that he would love to return to work, but the pain makes it too difficult. Dr. Kinnard assessed a 10 percent disability and testified that plaintiff was not yet ready to return to work, but could eventually return to light duty. But he would not be able to repeatedly climb in and out of the truck or change a fifty pound tire. Dr. Cenac, on the other hand, testified that plaintiff could probably return to driving trucks.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Delco v. Stafford
813 So. 2d 458 (Louisiana Court of Appeal, 2002)
Junot v. Morgan
818 So. 2d 152 (Louisiana Court of Appeal, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
813 So. 2d 458, 2001 La.App. 1 Cir. 0018, 2002 La. App. LEXIS 236, 2002 WL 241131, Counsel Stack Legal Research, https://law.counselstack.com/opinion/delco-v-stafford-lactapp-2002.