Roberts v. Aderhold

615 S.E.2d 761, 273 Ga. App. 642, 2005 Fulton County D. Rep. 1593, 2005 Ga. App. LEXIS 470
CourtCourt of Appeals of Georgia
DecidedMay 12, 2005
DocketA05A0148
StatusPublished
Cited by5 cases

This text of 615 S.E.2d 761 (Roberts v. Aderhold) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roberts v. Aderhold, 615 S.E.2d 761, 273 Ga. App. 642, 2005 Fulton County D. Rep. 1593, 2005 Ga. App. LEXIS 470 (Ga. Ct. App. 2005).

Opinions

Phipps, Judge.

In this medical malpractice action by parents for the wrongful death of their child, the jury returned a verdict in favor of the plaintiffs but awarded them no damages. The question on appeal is whether the trial court abused its discretion in granting the father’s motion for new trial on the issue of damages only. We find no abuse of discretion and affirm.

Plaintiffs, Maurice Aderhold and LaToya Hillman, conceived a child. Defendants, Dr. James Roberts and Dr. Robert Williams, provided Hillman with prenatal medical care. After the child was delivered stillborn, plaintiffs sued to recover for the child’s wrongful death. During the proceedings below, plaintiffs claimed that Hill-man’s gestational diabetes caused the stillbirth, and they charged [643]*643defendants with negligence in failing to diagnose Hillman’s condition. Defendants denied that they were negligent, and they charged Hillman with negligence in failing to disclose her family history of diabetes and in failing to follow their medical instructions. Negligence by Aderhold was not alleged.

The claims against Williams were settled before trial. At trial, the jury returned a verdict “in favor of the plaintiffs and against the defendant [Roberts] in the sum of $ -0-.” Alternatively, under the verdict form, the jury could have found “in favor of the defendant.” After the trial court entered judgment on the verdict, both Aderhold and Hillman moved for a new trial. The trial court ruled that Aderhold, but not Hillman, was entitled to a new trial and that the amount of damages was the only issue to be decided on retrial. In so ruling, the court determined that the jury was authorized to return a verdict in favor of Hillman awarding her no damages, but that the jury was not authorized to return a verdict in favor of Aderhold awarding him no damages. According to the trial court, the jury was authorized to find that the negligence of Roberts combined with the negligence of Hillman to cause the child’s death and that Hillman’s contributory negligence was of such degree as to bar her recovery of damages against Roberts, but the jury was not authorized to return such a verdict as to Aderhold because there was no evidence of negligence by him. We granted Roberts’s application for interlocutory appeal.

1. Roberts argues that the trial court erred in not interpreting the verdict as being based on a finding that he was not negligent. Roberts also argues that because the verdict awarded the plaintiffs no damages, the trial court was obligated to enter judgment on the verdict for the defense.

Recovery of damages is dependent on the applicable law and evidence.1

In order to maintain a cause of action for ordinary or professional negligence, a plaintiff must prove the following elements: (1) a legal duty to conform to a standard of conduct; (2) a breach of this duty; (3) a causal connection between the conduct and the resulting injury; and (4) damage to the plaintiff. [Cits.]2

“Verdicts shall have a reasonable intendment and shall receive a [644]*644reasonable construction. They shall not be avoided unless from necessity.”3 Therefore, verdicts are presumed valid, and if possible a construction will be given which will uphold them.4 There is also a presumption that the verdict of a jury is based on a fair consideration of all matters presented to it.5

Applying the foregoing presumptions, while giving the verdict a reasonable construction, the trial court was authorized to conclude that by returning a verdict “in favor of the plaintiffs,” rather than “in favor of the defendant,” the jury found that Roberts had breached a duty of care owed to the plaintiffs, that he had been negligent, and that any contributory negligence by Hillman was not the sole proximate cause of the child’s death, but that the plaintiffs should not recover damages.6 Under the facts of this case, however, Georgia law would not prohibit a recovery by Aderhold, although it might prohibit a recovery by Hillman.

If a jury finds that the defendant was negligent and that the plaintiff was also guilty of negligence which contributed to the injuries, Georgia’s comparative negligence rule provides that the plaintiff cannot recover if her negligence was “equal to or greater than” that of the defendant.7 But in wrongful death actions under OCGA § 19-7-1, the contributory negligence of a parent generally defeats recovery only in that parent.8

[T]he contributory negligence of one beneficiary in a wrongful death action does not defeat recovery when the right to recovery exists in multiple beneficiaries. [Cit.] Under Georgia law, the cause of action for the death of a child belongs to both parents jointly. [Cit.] Consequently, . . . contributory negligence... by [one of the parents] will not defeat recovery for [the other]. [Cit.]9
Moreover,
where the negligence of [one wrongful death beneficiary] and the defendant combine [s] to proximately cause the [645]*645death of [the decedent], the negligence of the [one beneficiary] d[oes] not bar the [other beneficiary’s] recovery even though the negligence of the [one beneficiary] was equal to or greater than the negligence of the defendant.10

Construing the evidence in a light most favorable to support the verdict, the trial court determined that the jury was authorized to find that even though Roberts was negligent, Hillman’s contributory negligence was equal to or greater than that of Roberts and thus defeated her right of recovery. Therefore, her motion for new trial was appropriately denied. Under Georgia law, however, Hillman’s contributory negligence would not defeat Aderhold’s right of recovery; and it is undisputed that Aderhold was not chargeable with any contributory negligence.

As argued by Roberts, “[generally, a zero damages verdict does result in a verdict for defendant.”11 Therefore, a judgment for the defendant generally should be entered on such a jury verdict;12 this is not, however, invariably true.13

In Peterson14 we held that a jury verdict in favor of the plaintiff that awarded him no damages was not improper, as the evidence authorized the jury to find that (even if the defendant was negligent) the plaintiff had caused his own injuries. In Palmer,15 we held that a jury returning a verdict such as the one in Peterson was authorized to find under the evidence that the plaintiff had not sustained any compensable damages as the proximate result of a collision (even if caused by the defendant’s negligence). In Gielow,16 we found no error in the trial court’s entry of judgment for the defendant on a jury verdict in favor of the plaintiffs but awarding them no damages, holding that the evidence authorized but did not demand a finding that the plaintiffs were entitled to damages.

On the other hand, in Rucker17

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Roberts v. Aderhold
615 S.E.2d 761 (Court of Appeals of Georgia, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
615 S.E.2d 761, 273 Ga. App. 642, 2005 Fulton County D. Rep. 1593, 2005 Ga. App. LEXIS 470, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roberts-v-aderhold-gactapp-2005.