Inconsistent jury verdict is upheld by court
Barbara Wood sued Robert and Denise Holiday in Oakland County Circuit Court, arguing that she fractured her ankle because of a dangerous condition on their land. The parties entered a series of stipulations, including the decision to tell the jury that Wood was covered by workers compensation, that she had redeemed her comp claim for $140,000.00 and that she had past medical of $28,000.00. Ultimately, the jury returned a verdict that was present-valued at approximately $150,000.00. Wood appealed, however, because the jury failed to award anything for past medical and awarded only $2600.00 in future non-economic damages (for pain and suffering). The bulk of the award was for future lost wages.
The Court of Appeals upheld the verdict, pointing out that under the complicated situation presented to the jury, a logical basis could support the jury's ultimate decision; if any logical explanation will support a verdict, it must be upheld. The court noted that unlike a prior case where the Court of Appeals had reversed a jury verdict that did not include stipulated medical expenses, in this case the jury could have concluded that the workers comp redemption had already compensated Wood. It also noted that there was evidence in the file from which the jury could have concluded that Wood was exaggerating her injuries or otherwise had failed to mitigate her losses: therefore, the jury was free to award any amount it deemed reasonable for pain and suffering.