Aundrey MEALS Ex Rel. William MEALS v. FORD MOTOR COMPANY
2013 Tenn. LEXIS 702
| Tenn. | 2013Background
- Six-year-old Billy Meals suffered permanent paraplegia from a lap-seatbelt injury in a 2002 Memphis crash involving a Ford-manufactured 1995 Mercury Grand Marquis.
- Plaintiff sued Ford for negligence, faulty design, failure to warn, and related tort theories seeking compensatory and punitive damages.
- Jury found Ford 15% at fault and non-parties 85% at fault; Ford’s share was $6.57 million; no punitive damages.
- Court of Appeals reduced the award by 70.55% (to $12.9 million) via remittitur without Ford requesting it.
- Tennessee Supreme Court held the Court of Appeals lacked authority to reduce the jury award to that extent; the verdict was within the range of reasonableness and reinstated the $43.8 million verdict, with Ford’s share $6.57 million.
- Case remanded for further proceedings consistent with reinstatement; costs taxed to Ford and its surety.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Appeals could suggest remittitur when the trial judge affirmed the verdict as thirteenth juror | Meals: Court of Appeals had authority to suggest remittitur | Ford: Court of Appeals lacked authority to reduce; remittitur not appropriate | Court of Appeals erred; remittitur not properly applied and verdict reinstated |
| Whether the jury’s damages award was within the range of reasonableness and supported by material evidence | Meals: damages supported by biomedical and life-expectancy evidence | Ford: award excessive and should be reduced | Verdict within range of reasonableness and supported by material evidence; reinstated at full amount |
| Whether statutory non-economic damages cap affected this case | Plaintiff argues cap not applicable to pre-cap injuries | Ford argues cap limits damages | Court notes post-2011 cap; analysis focused on evidence; cap discussed as context but not applied to reinstate the verdict in this pre-cap injury |
| What standard governs appellate review when trial judge affirms verdict as thirteenth juror | Review is deferential to jury verdict | Review limited to material evidence if judge affirmed | Appellate review adheres to material-evidence standard when judge affirms as thirteenth juror |
Key Cases Cited
- Holden v. Rannick, 682 S.W.2d 903 (Tenn. 1984) (thirteenth juror concept and damages review)
- Spence v. Allstate Ins. Co., 883 S.W.2d 586 (Tenn. 1994) (general damages principles; range of damages)
- Ellis v. White Freightliner Corp., 603 S.W.2d 125 (Tenn. 1980) (range of reasonableness; remittitur framework)
- Turner v. Jordan, 957 S.W.2d 815 (Tenn. 1997) (remittitur procedure; statutory basis (20-10-102))
- Foster v. Amcon Int’l, Inc., 621 S.W.2d 142 (Tenn. 1981) (remittitur as alternative to new trial; range of reasonableness)
- Potter v. Ford Motor Co., 213 S.W.3d 264 (Tenn. Ct. App. 2006) (similar case; liability issue; not directly on damages review)
- Palanki ex rel. Palanki v. Vanderbilt Univ., 215 S.W.3d 380 (Tenn. Ct. App. 2006) (remittitur context; economic vs non-economic damages)
- Duran v. Hyundai Motor Am., Inc., 271 S.W.3d 178 (Tenn. Ct. App. 2008) (remittitur depends on evidence; guidance on non-economic damages)
- Thrailkill v. Patterson, 879 S.W.2d 836 (Tenn. 1994) (remittitur guidance; cost efficiency of remittitur)
- Coffey v. Fayette Tubular Prods., 929 S.W.2d 326 (Tenn. 1996) (limits on remittitur scope when verdict affirmed as thirteenth juror)
- S. Ry. Co. v. Sloan, 56 Tenn. App. 380, 407 S.W.2d 205 (1965) (evidence review and range of damages; guidance on evaluating verdicts)
- Akers v. Prime Succession of Tenn., Inc., 387 S.W.3d 495 (Tenn. 2012) (material evidence standard; deferential to jury verdict)