Ahmad v. State, 432 P.3d 932

During a law-enforcement pursuit, a suspect’s vehicle struck and killed Alex Ahmad; his parents Shuja and Margaret Ahmad sued the State of Arizona for wrongful death alleging the pursuit was unnecessary and dispatch failures.
A jury found for the Ahmads, awarding $30 million in damages and apportioning 5% fault to the State.
The State moved for remittitur or a new trial on damages; the superior court reduced the award to $10 million and granted a conditional new trial if the plaintiffs rejected the reduction.
The Ahmads rejected the reduced award and appealed; this court previously reversed the remittitur (Ahmad I), the Arizona Supreme Court vacated and remanded for reconsideration in light of Soto v. Sacco.
On remand this court applied Soto’s remittitur standards and reversed the superior court again because the remittitur order lacked the required particularized findings and the record did not supply substantial evidence supporting the reduction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the superior court satisfied Soto’s requirement to state particularized grounds for remittitur	The court’s terse statement was insufficient; the jury’s $30M award was supported by evidence of significant non‑economic loss	The court’s reduction to $10M was proper and justified by trial record and comparison to other verdicts	Court held the superior court failed to state particularized grounds as required by Soto and abused its discretion; remittitur reversed; judgment on jury verdict directed
Whether the $30M award was excessive because it consisted of non‑economic damages	Non‑economic damages for loss of companionship and profound emotional distress supported the amount; jury properly exercised its statutory authority	Award was excessive, unsupported by economic loss and comparable verdicts	Court held wrongful‑death law allows significant non‑economic awards; evidence supported jury’s role and no showing of passion or prejudice
Whether references to punitive or otherwise unavailable damages tainted the verdict	Jury was properly instructed and limited to compensatory damages; presumption that jury followed instructions	Counsel’s remarks invited punitive considerations, justifying reduction	Court held instructions were adequate; no basis to infer jury awarded punitive damages and state failed to show remittitur supported by substantial evidence

Ahmad v. State, 240 Ariz. 380 (App. 2016) (earlier reversal of superior court remittitur order)
Soto v. Sacco, 242 Ariz. 474 (2017) (articulates remittitur standard and requires particularized grounds)
State v. Fischer, 242 Ariz. 44 (2017) (discusses trial-court consideration of new‑trial motions)
Walsh v. Advanced Cardiac Specialists Chartered, 229 Ariz. 193 (2012) (describes wrongful‑death damages scope)
Hernandez v. State, 128 Ariz. 30 (App. 1980) (jury’s role in translating loss of companionship into monetary damages)
City of Phoenix v. Whiting, 10 Ariz. App. 189 (App. 1969) (statutory scheme provides broad base for measure of wrongful‑death damages)