Snyder v. Halsey

19 Pa. D. & C.5th 362
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedNovember 22, 2010
Docketno. 05-13134
StatusPublished

This text of 19 Pa. D. & C.5th 362 (Snyder v. Halsey) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Snyder v. Halsey, 19 Pa. D. & C.5th 362 (Pa. Super. Ct. 2010).

Opinion

SILOW, J.,

Appellants, Jennifer

and James Snyder, h/w (“appellants”), appeal from this court’s order of September 7, 2010, denying their motion for a new trial. For the reasons set forth below, the September 7, 2010 order should be affirmed.

FACTS AND PROCEDURAL HISTORY

This case involved a motor vehicle accident that occurred on May 10, 2003, when a vehicle operated by appellee, Amber Kay Halsey (“appellee”), rear-ended appellants’ vehicle, allegedly causing appellant, Jennifer Snyder, injury.1 Prior to trial, the parties stipulated that appellee was negligent and that Mrs. Snyder’s out-of-pocket medical expenses were $14,134.31. After a two-day jury trial (consisting of eight jurors) that commenced on May 3,2010, the jury found by a preponderance of the evidence that appellee’s negligence was a factual cause of Mrs. Snyder’s damages, and awarded Mrs. Snyder $14,134.31 to compensate her for her medical expenses. The juiy declined to award Mrs. Snyder noneconomic damages. In addition, the jury did not award appellant, James Snyder, any damages for loss of consortium.

On May 10, 2010, appellants filed a motion for new trial, arguing that the jury’s verdict was against the weight of the evidence. After a hearing, this court denied appellants’ motion on September 7, 2010. On October 5, 2010, appellants noticed their appeal of this denial. On October 7, 2010, this court directed appellants to file a concise statement of errors complained of on appeal [365]*365(the “concise statement”) within twenty-one (21) days, appellants filed their timely concise statement on October 25,2010.

ISSUES

In their concise statement, appellants raise the following allegations of error against this court:

1. Whether the trial court erred in denying appellants ’ motion for new trial on the question of damages for pain and suffering and loss of consortium?
2. Whether the jury’s verdict on the question of pain and suffering and loss of consortium were against the weight of the evidence?

DISCUSSION

1 & 2. This court properly denied appellants’ motion for new trial.2

A. Standard of Review.

Appellants’ motion for new trial asserted that the jury’s verdict of no noneconomic damages was against the weight of the evidence; appellants sought a new trial on the issue of damages only. “Trial courts have broad discretion to grant or deny a new trial.” Zelger v. Detweiler, 835 A.2d 764, 767 (Pa. Super. 2003). When a challenge to a new trial is appealed, the proper standard of review is whether the trial court abused its discretion. Harman ex rel. Harman v. Borah, 562 Pa. 455, 466, 756 A.2d 1116, 1122 (Pa. 2000). “An appellate court may reverse the trial [366]*366court’s decision only if it finds no basis on the record to support the reasons offered by the trial court.” Zeiher, 835 A.2d at 767.

“A new trial should be awarded on the ground that the verdict is against the weight of the evidence only when the jury’s verdict is so contrary to the evidence as to shock one’s sense of justice and the award of a new trial is imperative so that right may be given another opportunity to prevail.” Burrell v. Philadelphia Electric Co., 265 A.2d 516, 518 (Pa. 1970). “A new trial should not be granted because of a mere conflict in testimony or because the trial judge on the same facts would have arrived at a different conclusion...Neither should it ordinarily be granted on the ground that the verdict was against the weight of the evidence where the evidence is conflicting and the jury might have found for either party.” Id (citations omitted)

B. Although the jury found that the motor vehicle accident was the factual cause of injury, the jury was not required to award Mrs. Snyder noneconomic damages.

In the present case, the jury found that appellee’s negligence (which was stipulated to) was the factual cause of Mrs. Snyder’s injury. Additionally, both parties’ experts agreed at trial that Mrs. Snyder sustained some injury as a result of the motor vehicle accident, although there remained a question as to the extent of such injury. The jury awarded Mrs. Snyder $ 14,134.31 to compensate her for the medical expenses she incurred out-of-pocket. Appellants contended that Pennsylvania law also mandated the juiy to award Mrs. Snyder past, present or future noneconomic damages (pain and suffering, loss of enjoyment of life, and embarrassment and humiliation).

[367]*367Where both parties’ medical experts agree that an accident caused the plaintiff harm, a jury cannot find that the plaintiff did not suffer some injury. See Andrews v. Jackson, 800 A.2d 959 (Pa. Super. 2002). In Andrews, the parties’ experts agreed that a car accident caused the plaintiff to suffer some injury. The jury in that case found the defendant negligent but did not find that the accident caused an injury, and therefore awarded the plaintiff no damages. The Superior Court ruled that the trial court’s failure to grant a new trial was error.

The instant case, however, is distinguishable from cases such as Andrews in that this jury did find that appellee’s negligent act was the factual cause of injury to Mrs. Snyder. This is what is required by Pennsylvania law. A jury is free to determine the amount of damages, if any, a plaintiff suffered. In this case, the jury found that Mrs. Snyder should be compensated for her out-of-pocket medical expenses but found, based upon the evidence at trial, that her injury was not severe enough for her to have incurred noneconomic damages such as pain and suffering, loss of life’s pleasures, and embarrassment and humiliation.

A jury that finds causation is not required to award noneconomic damages in every case. In Davis v. Mullen, 565 Pa. 386, 773 A.2d 764 (Pa. 2001), the Pennsylvania Supreme Court held that the jury’s award of medical expenses without a corresponding award of damages for pain and suffering was not necessarily inconsistent.3 Rather, a jury’s verdict of medical expenses only “should not be [368]*368disturbed where there is reasonable basis to believe that: (1) the jury did not believe the plaintiff suffered any pain and suffering, or (2) that a preexisting condition or Injury was the sole cause of the alleged pain and suffering.” Id. at 767. In the instant case, there was plentiful evidence for the juiy to reasonably find the existence of one or both of these options, as is discussed infra. Additionally, it should be noted that “[jjuries are not to be faulted...if they do not believe all they are told and all that common experience does not accept. That is not to say they may disregard an obvious injury. It is, however, to say that they are not obliged that every injury causes pain or the pain alleged.” Id. (citations omitted)

C.

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Related

Andrews v. Jackson
800 A.2d 959 (Superior Court of Pennsylvania, 2002)
Harman Ex Rel. Harman v. Borah
756 A.2d 1116 (Supreme Court of Pennsylvania, 2000)
Dougherty v. McLaughlin
637 A.2d 1017 (Superior Court of Pennsylvania, 1994)
Davis v. Mullen
773 A.2d 764 (Supreme Court of Pennsylvania, 2001)
Burnhauser v. Bumberger
745 A.2d 1256 (Superior Court of Pennsylvania, 2000)
City of Philadelphia v. Buck
587 A.2d 875 (Commonwealth Court of Pennsylvania, 1991)
Zeigler v. Detweiler
835 A.2d 764 (Superior Court of Pennsylvania, 2003)
Marsh v. Hanley
856 A.2d 138 (Superior Court of Pennsylvania, 2004)
Burrell v. Philadelphia Electric Co.
265 A.2d 516 (Supreme Court of Pennsylvania, 1970)

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Bluebook (online)
19 Pa. D. & C.5th 362, Counsel Stack Legal Research, https://law.counselstack.com/opinion/snyder-v-halsey-pactcomplmontgo-2010.