Donlon v. City of New York

284 A.D.2d 13, 727 N.Y.S.2d 94, 2001 N.Y. App. Div. LEXIS 6710
CourtAppellate Division of the Supreme Court of the State of New York
DecidedJune 28, 2001
StatusPublished
Cited by61 cases

This text of 284 A.D.2d 13 (Donlon v. City of New York) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Donlon v. City of New York, 284 A.D.2d 13, 727 N.Y.S.2d 94, 2001 N.Y. App. Div. LEXIS 6710 (N.Y. Ct. App. 2001).

Opinions

OPINION OF THE COURT

Per Curiam.

This is an appeal from a money judgment based upon a jury verdict awarding plaintiff damages for past and future pain and suffering. The defendant contends that the award is excessive. This requires our review pursuant to CPLR 5501 (c). The issue is whether the award is excessive in that it deviates materially from what would be reasonable compensation. For the reasons set forth below we find that the award for future pain and suffering is excessive in that it deviates materially from what would be reasonable compensation and should be reduced by 20% to $400,000.

CPLR 5501 (c), as amended by Laws of 1986 (ch 682, § 10), one of many tort reform innovations added in the mid-1980s, requires that:

“In reviewing a money judgment in an action in which an itemized verdict is required by rule forty-one hundred eleven of this chapter in which it is contended that the award is excessive or inadequate and that a new trial should have been granted unless a stipulation is entered to a different award, the appellate division shall determine that an award is excessive or inadequate if it deviates materially from what would be reasonable compensation.”

CPLR 5522 (b) requires that we identify the reasons for our decision. This case, as briefed and argued by the parties, involves the future pain and suffering award to a man in his thirties who fell 25 feet, fractured two vertebrae, recovered and returned without any restrictions to his former employment which requires regular sudden and sustained physical exertion including heavy lifting. Our review does not involve plaintiffs economic losses and does not involve the jury’s award for past pain and suffering. The legislative scheme, fashioned as a remedy for an insurance crisis marked by spiraling costs and unavailability of liability coverage, requires that we look to similar appealed verdicts and exercise our judgment to promote greater stability in the tort system and greater fairness for similarly situated defendants (Exec Mem in Support of L 1986, [15]*15ch 682, 1986 McKinney’s Session Laws of NY at 3184; see generally Gasperini v Center for Humanities, 518 US 415, 422-425; Thomas Newman, New York Appellate Practice § 4.10). The 1986 tort reforms were occasioned by an insurance crisis, a main determinant of which was the “laws and doctrines governing civil liability for money damages in New York State” (Hugh R. Jones, Insuring Our Future — Report of the Governor’s Advisory Commission on Liability Insurance, Apr. 7, 1986 at 39). The Jones Commission Report (on which the legislative, reforms were based) focused on pain and suffering awards as a driving force behind the “cost surge” which threatened the ability to obtain insurance coverage and posed a threat to self-insured municipal corporations (.Insuring Our Future at 137-152). The Jones Commission recommended a $250,000 cap on non-economic damages against municipal corporations due to inherent problems with jury determinations of reasonable compensation:

“All of us are moved by the pain and anxiety that most people who suffer more than minor injuries go through. Our natural tendency is to want to help. Inasmuch as there is no objective way to value these harms, our inclination is to err on the high side. Over time, this tendency gathers its own momentum, a momentum which has no natural curbing force. Particularly in an era where the existence of insurance is commonly assumed, so that the defendant is not expected to bear most of the loss, the urge to provide the most assistance possible becomes nearly irresistible.” (Insuring Our Future at 85).

Although the Legislature ultimately rejected the Jones Commission recommendation to impose a $250,000 cap on non-economic damages in personal injury awards against municipal corporations, CPLR 5501 (c) was adopted as a reform to the former “shock the conscience” appellate review of damage awards. The “natural curbing force” to check the upward spiral of non-economic jury awards is the review which we are charged to perform by CPLR 5501 (c).

The method of that review is to evaluate whether the appealed award deviates materially from comparable awards. Such a method cannot, due to the inherently subjective nature of non-economic awards, be expected to produce mathematically precise results, much less a per diem pain and suffering rate. Our task necessarily involves identification of relevant factual similarities and the application of reasoned judgment.

[16]*16Appellate review under CPLR 5501 (c) has also, alternatively, determined “reasonableness” by whether or not the jury’s decision is in any way supported by record evidence (Simeon v Urrey, 278 AD2d 624; Rodriguez v City of New York, 191 AD2d 420). The 1986 amendment to CPLR 5501 (c) replaced the prior “shocks the conscience” review (Harvey v Mazal Am. Partners, 79 NY2d 218, 225). This new standard “in design and operation, influences outcomes by tightening the range of tolerable awards.” (Gasperini v Center for Humanities, 518 US 415, 425.) For more than a decade appellate review has been performed by analogizing an appealed case with relevant precedent and “tightening the range” to accomplish the purposes of the 1986 reform. The present appeal involves case comparison reasonableness.

While the dissent characterizes appellate court comparison of cases as a “tenuous endeavor,” analysis of appealed verdicts using CPLR 5501 (c) is not optional but a legislative mandate. Case comparison cannot be expected to depend upon perfect factual identity. More often, analogous cases will be useful as benchmarks. Perceived difficulties in the application of a legal standard, while they may suggest a need for the Legislature to consider reform or repeal, cannot provide a basis for judicial nullification of the current law. Review of jury verdicts often involves questions of fact on which the trier of fact is afforded deference; the issue of material deviation, however, is a mixed question of law and fact which has been legislatively committed to judicial oversight. (See NY Const, art VI, § 30; Cohn v Borchard Affiliations, 25 NY2d 237.) The dissent casts this appealed future pain and suffering verdict as a question of fact. No jury can determine the issue of material deviation and we cannot, consistent with CPLR 5501 (c), attempt to use the rationale of deference to a jury verdict in resolving that issue \Vhen we are supposed to compare ánalogous verdicts. While we agree with plaintiff that the jury verdict does not deviate materially with respect to the amount awarded as compensation for past pain and suffering ($400,000), we find that the award for future pain and suffering ($500,000) deviates materially from what is reasonable compensation and should be reduced by 20% to $400,000.

William Donlon is a New York City firefighter who sustained serious injuries to his back in October 1992 when he fell 25 feet through a hole in the firehouse second floor where the sliding pole was situated. Plaintiff’s injuries of two fractured lumbar vertebrae and a herniation of a third vertebra resulted [17]*17in hospitalization for eight days and a three-month return to his mother’s home, where he received assistance for most activities of daily living. Treatment for his injuries ranged from the administration of pain medication during his hospital stay to the wearing of a corset for six months. At the end of six months, plaintiff returned to part-time duty which consisted of security and clerical work.

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

Related

Couteller v. Mamakos
2025 NY Slip Op 06965 (Appellate Division of the Supreme Court of New York, 2025)
Burgess v. Little Wolf Cabinet Shop, Inc.
2025 NY Slip Op 32504(U) (New York Supreme Court, Kings County, 2025)
Mejia v. Japan Socy., Inc.
2025 NY Slip Op 50119(U) (New York Supreme Court, Bronx County, 2025)
Brown v. Voda Realty LLC
2024 NY Slip Op 03129 (Appellate Division of the Supreme Court of New York, 2024)
J.M. v. Rozanov
2024 NY Slip Op 24132 (New York Supreme Court, Bronx County, 2024)
Sinera v. Embassy House Eat LLC
2024 NY Slip Op 00057 (Appellate Division of the Supreme Court of New York, 2024)
Gonzalez v. United States
80 F.4th 183 (Second Circuit, 2023)
Small v. City of New York
2023 NY Slip Op 00749 (Appellate Division of the Supreme Court of New York, 2023)
Appleyard v. Tigges
2023 NY Slip Op 00260 (Appellate Division of the Supreme Court of New York, 2023)
Wynter v. Transdev Servs., Inc.
207 A.D.3d 785 (Appellate Division of the Supreme Court of New York, 2022)
Fortune v. New York City Hous. Auth.
161 N.Y.S.3d 283 (Appellate Division of the Supreme Court of New York, 2022)
Rojas v. Brabant
2021 NY Slip Op 08271 (Appellate Division of the Supreme Court of New York, 2021)
Thomas v. New York City Hous. Auth.
2020 NY Slip Op 1001 (Appellate Division of the Supreme Court of New York, 2020)
Carino v. Friendly Fruit, Inc.
2019 NY Slip Op 8373 (Appellate Division of the Supreme Court of New York, 2019)
Dacaj v. New York City Tr. Auth.
2019 NY Slip Op 2171 (Appellate Division of the Supreme Court of New York, 2019)
Frankel v. Vernon & Ginsburg, LLP
2018 NY Slip Op 2577 (Appellate Division of the Supreme Court of New York, 2018)
Matter of 91st St. Crane Collapse Litig.
2017 NY Slip Op 6419 (Appellate Division of the Supreme Court of New York, 2017)
Leo v. Lomma
154 A.D.3d 139 (Appellate Division of the Supreme Court of New York, 2017)
McDonald v. Baobob, Inc.
Appellate Terms of the Supreme Court of New York, 2016
Cardoza v. City of New York
139 A.D.3d 151 (Appellate Division of the Supreme Court of New York, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
284 A.D.2d 13, 727 N.Y.S.2d 94, 2001 N.Y. App. Div. LEXIS 6710, Counsel Stack Legal Research, https://law.counselstack.com/opinion/donlon-v-city-of-new-york-nyappdiv-2001.