Miguel Escobar v. A&A Orchard, LLC

2021 Ark. App. 128, 620 S.W.3d 534
CourtCourt of Appeals of Arkansas
DecidedMarch 17, 2021
StatusPublished
Cited by1 cases

This text of 2021 Ark. App. 128 (Miguel Escobar v. A&A Orchard, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miguel Escobar v. A&A Orchard, LLC, 2021 Ark. App. 128, 620 S.W.3d 534 (Ark. Ct. App. 2021).

Opinion

Cite as 2021 Ark. App. 128 ARKANSAS COURT OF APPEALS Elizabeth Perry I attest to the accuracy and DIVISION IV integrity of this document No. CV-20-7 2023.06.23 10:22:41 -05'00' 2023.001.20174 Opinion Delivered March 17, 2021

MIGUEL ESCOBAR APPEAL FROM THE CARROLL APPELLANT COUNTY CIRCUIT COURT, EASTERN DISTRICT V. [NO. 08ECV-18-141]

A&A ORCHARD, LLC HONORABLE SCOTT JACKSON, APPELLEE JUDGE

AFFIRMED IN PART; REVERSED AND REMANDED IN PART

STEPHANIE POTTER BARRETT, Judge

Miguel Escobar appeals the judgment entered in his negligence action against his

employer, A&A Orchard, LLC. Escobar argues that the circuit court erred in (1) denying

his motion for new trial, (2) failing to properly instruct the jury, and (3) reducing the

judgment by the amount paid by A&A Orchard’s insurance carrier for Escobar’s medical

expenses. We affirm in part and reverse and remand in part.

In June 2018, Escobar filed a complaint against A&A Orchard alleging that it had

committed negligence when it required him to climb a “wobbly ladder in windy weather.”

Escobar fell from the ladder and alleged damages including partial amputation of a finger,

medical bills, lost wages, and pain and suffering. The case was ultimately decided by a jury,

which found A&A Orchard 51 percent at fault and Escobar 49 percent at fault. The jury

awarded Escobar $17,976.12 in damages and, by separate interrogatory, specifically found

1 $14,976.12 of those damages constituted the reasonable expense of medical care, treatment,

and services. Because medical-care expenses had already been paid by A&A Orchard’s

insurance carrier, the circuit court set aside that portion of the judgment. Escobar was

therefore awarded $1,530, which is 51 percent of the remaining $3,000 award.

Escobar has appealed the judgment and the denial of his motion for new trial. He

argues that the jury’s verdict was clearly contrary to the preponderance of the evidence.

Specific facts related to the arguments on appeal will be discussed below.

I. Motion for New Trial

At trial, the circuit court instructed the jury that if it decided for Escobar on the

question of liability, it must then fix the amount of money

which will reasonably and fairly compensate him for any of the following four [sic] elements of damage . . . which you find were proximately caused by the negligence of A&A Orchard.

First: The nature, extent, and duration of any injury and whether it is temporary or permanent.

Second: The reasonable expense of any necessary medical care, treatment, and services received, including transportation expenses necessarily incurred in securing such care, treatment, or services.

Third: Any pain and suffering and mental anguish experienced in the past and reasonably certain to be experienced in the future.

Four: The value of any lost—any earnings lost.

And five: Any scars, disfigurement, and visible results of his injury.

The circuit court also explained that the jury must answer five interrogatories: One,

whether it found negligence on the part of A&A Orchard; two, whether it found negligence

on the part of Escobar; three, if yes to numbers one or two, then the apportionment of fault

2 between the parties using 100 percent as the total amount of fault; four, if less than 50

percent of fault is apportioned to Escobar, then the amount of damages sustained by Escobar;

five, of the damages fixed in number four, what amount of those damages constitute the

reasonable expense of any necessary medical care, treatment, and services.

During deliberations, the jury sent a note asking, “Can we do just lost wages and

medical expenses? If so, how do we put that down on the paper?” The circuit court

responded by again explaining the instructions on answering the interrogatories. The jury

later returned a verdict as explained above.

In his motion for new trial, Escobar argued that, despite the uncontested nature of

his damages—including a painful injury and visible disfigurement by partial loss of his pinky

finger—the jury’s note evinced its intent to disregard three of the five elements of damages

and award damages only for medical expenses and lost wages. Escobar urged that the jury

had failed to consider all the elements of his damages.

A&A Orchard countered that Escobar had presented no medical testimony or other

medical evidence, apart from medical bills, to establish the damages sought; that Escobar’s

treating physician testified during A&A Orchard’s case-in-chief that Escobar was in no acute

distress, that his pain was well controlled, that he had no complications, and that he did not

return for any follow-up visits; and Escobar offered no evidence to rebut the treating

physician’s testimony. A&A Orchard also stressed the jury’s finding that Escobar was 49

percent at fault. In denying the motion for new trial, the circuit court found that “the jury

was properly instructed as to all the elements of damage” and that the jury had not

“improperly disregarded any one of these elements.”

3 When the primary issue is the alleged inadequacy of the damages award, we will

affirm the denial of a motion for a new trial absent a clear and manifest abuse of discretion.

Fritz v. Baptist Mem’l Health Care Corp., 92 Ark. App. 181, 211 S.W.3d 593 (2005). An

important consideration is whether a fair-minded jury could have reasonably fixed the award

at the challenged amount. Depew v. Jackson, 330 Ark. 733, 957 S.W.2d 177 (1997).

On appeal, Escobar contends that no fair-minded jury could reasonably find that the

loss of part of a finger resulted in no pain, disability, or disfigurement, nor could the circuit

court have reasonably or fairly concluded that the jury took into account all of his damages.

Escobar cites Tirado v. O’Hara, 70 Ark. App. 152, 15 S.W.3d 715 (2000), in support of his

argument. In Tirado, the circuit court granted a motion for new trial in a medical-

malpractice action after the jury awarded damages only for a patient’s actual monetary losses

even though the record left no doubt that the patient’s femoral nerve had been damaged,

that the injury manifested itself in the form of pain in his leg, and that the injury was most

likely to some degree permanent. This court held that the circuit court could fairly conclude

that the jury failed to consider all the elements of the patient’s damages and did not abuse

its discretion in granting a new trial. Escobar contends that the evidence in his case is even

stronger than in Tirado and that it was an abuse of discretion for the circuit court to find that

the jury did not improperly disregard three of the elements of damage.

A&A Orchard responds that Tirado is distinguishable from this case. The patient in

Tirado offered the testimony of seven physicians to describe his medical treatments and his

damages, including pain suffered and permanency of the injury. Escobar presented no

testimony from any physician on any point. No medical records concerning his treatment

4 and condition and prognosis were presented either. Only medical bills were introduced at

trial. The only witnesses who testified in Escobar’s case-in-chief were Escobar and the

owner of A&A Orchard, John Aselage.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
2021 Ark. App. 128, 620 S.W.3d 534, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miguel-escobar-v-aa-orchard-llc-arkctapp-2021.