May v. William Beaumont Hospital

448 N.W.2d 497, 180 Mich. App. 728
CourtMichigan Court of Appeals
DecidedNovember 6, 1989
DocketDocket 93511
StatusPublished
Cited by22 cases

This text of 448 N.W.2d 497 (May v. William Beaumont Hospital) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
May v. William Beaumont Hospital, 448 N.W.2d 497, 180 Mich. App. 728 (Mich. Ct. App. 1989).

Opinions

MacKenzie, P.J.

We agree with Judge Cynar’s disposition of all claims raised on appeal, except the amount of remitted damages Robert Kolosowski should have been awarded.

As a general rule, awards for personal injury rest within the sound judgment of the trier of fact. If the amount awarded falls reasonably within the range of evidence and within the limits of what reasonable minds would deem just compensation for the injury sustained, the verdict should not be disturbed. Precopio v Detroit, 415 Mich 457; 330 NW2d 802 (1982). However, where a jury’s award is greater than the highest amount the evidence will support, remittitur is proper. See Palenkas v Beaumont Hospital, 432 Mich 527; 443 NW2d 354 (1989). This Court may only disturb a grant of remittitur if an abuse of discretion is shown. Palenkas, supra.

In this case, the trial court remitted the jury’s $5,000,000 award to $106,696.01. As Judge Cynar’s opinion details, the trial court in reaching this remitted amount committed a number of legal and factual errors. While we are cognizant of our duty to afford due deference to the decision of the trial judge, Palenkas, supra, in light of these errors we conclude that the trial court abused its discretion [733]*733in its grant of remittitur. Based upon an objective review of the evidence, Palenkas, supra, we are of the opinion that the proofs reasonably support a remitted total award of $1,265,843.84.

As Precopio, supra, and Judge Cynar’s opinion indicate, damages in personal injury cases may compensate the plaintiff for both economic losses (such as lost wages and expenses associated with the plaintiff’s injury) and for noneconomic losses (including pain, disability, and lost enjoyment).

We agree with Judge Cynar’s opinion that the remitted award for Robert Kolosowski’s economic losses constituted an abuse of discretion. For the reasons stated in Judge Cynar’s opinion, we are satisfied that the evidence in this case warranted an award to Robert Kolosowski of $315,843.84 for his future economic losses.

We also conclude that the trial court’s remitted award to plaintiff for his noneconomic losses constituted an abuse of discretion. In assessing the appropriateness of an award for noneconomic losses, analogous cases provide a sense of a reasonable range of awards. Precopio, supra, pp 471-472. The awards in the analogous cases must be adjusted for the difference between purchasing power in the year of those judgments and the year of the judgment under consideration. Precopio, supra, p 474, n 26. The judgment in this case was rendered in 1985. Cases involving injuries analogous to those suffered by Robert Kolosowski demonstrate a range of awards from approximately $182,000 to approximately $1,111,500 in 1985 dollars.1 Only where the brain damage sustained by the plaintiff [734]*734resulted in profound retardation,2 or was accompanied by disfigurement and emotional disorders,3 have courts exceeded the above range.4

In Sewar v Gagliardi Bros Service, 69 AD2d 281; 418 NYS2d 704 (1979), a twelve-year-old struck by a bus suffered a fractured skull, brain damage, restricted sight and hearing, and some spasticity. The plaintiff’s iq was measured at between fifty-seven and sixty-three, and she was deemed educable to the third-grade level, with an extremely limited social and occupational future. Remitted damages were $750,000 (approximately $1,111,500 in 1985 dollars) for pain and suffering and permanent disability. The remittitur was affirmed.

In Herman v Milwaukee Children’s Hospital, 121 Wisc 2d 531; 361 NW2d 297 (1984), a ten-year-old suffered a reduced iq of eighty-five (dull normal range) as a result of medical malpractice. A jury awarded the plaintiff over $2,000,000 for past and future pain, suffering, and disability. On appeal, the award was reduced to $925,000 (approximately $958,300 in 1985 dollars), as that was the highest amount plaintiff’s attorney requested the jury to award.

In Coastal States Gas Producing Co v Locker, [735]*735436 SW2d 592 (Tex Civ App, 1968), a five-year-old suffered permanent brain damage in an automobile accident. The boy was left with an iq of seventy-eight and he exhibited behavioral problems. A jury awarded him $400,000 for mental impairment, anguish, and lost earning capacity. On appeal, the court determined that this award should have been remitted to $300,000 (approximately $927,600 in 1985 dollars), including an award for lost earning capacity.

In Stanley v Ford Motor Co, 49 AD2d 979; 374 NYS2d 370 (1975), the plaintiff suffered permanent brain damage impairing his physical and mental coordination. Evidence established that his educational ability was severely limited and future employment would be confined to menial tasks. Additionally, there was a likelihood the plaintiff would develop seizure and emotional disorders. An award of $315,000 (approximately $687,000 in 1985 dollars), which included the present value of lost future earnings, was upheld as not excessive.

In Stanley v Wiley, 325 So 2d 661 (La App, 1975), the thirteen-year-old plaintiff suffered head injuries in a truck accident, resulting in intellectual impairment to the dull-normal range, physical impairment of skilled movement, impaired judgment, and impaired memory. Noting that the plaintiff’s changed appearance would diminish her social life and that her vocational prospects were poor, the court upheld a general award of $275,000 (approximately $550,000 in 1985 dollars).

In Masters v Alexander, 424 Pa 65; 225 A2d 905 (1967), a twelve-year-old child was awarded $100,000 (approximately $359,600 in 1985 dollars) for disfigurement, permanent lessening of earning capacity, physical and mental pain and discomfort, and personality change. His injuries included a fractured skull, eye damage, and permanent brain [736]*736damage leaving him unable to do or carry through anything but the most menial form of work. Additionally, the plaintiff sustained scarring of the face and head with a deformity and depression of the forehead.

In Watts v Town of Homer, 301 So 2d 729 (La App, 1974), a seventeen-month-old child was struck on the head with a metal pole, resulting in a fractured skull, swollen brain, and frequent convulsions. The child was unconscious for eight days, and holes had to be drilled in her skull. At the time of trial, left side paralysis was diminishing but affected her gait, her IQ was approximately fifty, and she was unable to attend school due to problems associated with convulsions. Because she required constant supervision and continual medication, she was deemed unable to work. The court remitted her general damages to $150,000 (approximately $327,000 in 1985 dollars).

Finally, in Smolinski v Taulli, 285 So 2d 577 (La App, 1973), a nineteen-month-old child fell, suffering a skull fracture. The child became hyperkinetic, exhibited slow motor development and slow toilet training, had difficulty with speech, and was in the dull or below normal intelligence range. A general award of $75,000 (approximately $182,000 in 1985 dollars) was held not excessive.

Based upon a review of the proofs and the above survey of analogous cases, we are persuaded that the highest award which can be justified for Robert Kolosowski’s past and future noneconomic losses is $950,000.

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May v. William Beaumont Hospital
448 N.W.2d 497 (Michigan Court of Appeals, 1989)

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Bluebook (online)
448 N.W.2d 497, 180 Mich. App. 728, Counsel Stack Legal Research, https://law.counselstack.com/opinion/may-v-william-beaumont-hospital-michctapp-1989.