651 F. App'x 270
5th Cir.2016Background
- Wiltz sued Welch and State Farm after Welch rear-ended his car; defendants admitted fault; case removed to federal court on diversity grounds and tried to a jury.
- Central dispute: whether Welch’s negligence caused compensable injuries (objective injuries) or merely justified precautionary medical care.
- Trial revealed Wiltz had multiple prior accidents and preexisting injuries which he failed to fully disclose; credibility issues at trial were significant.
- Jury awarded past medical expenses but denied general damages (pain and suffering), lost wages, and future medical expenses.
- Wiltz moved for a new trial (or amendment) arguing the award of medical expenses without general damages is legally inconsistent under Louisiana law; district court denied relief and Wiltz appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the jury verdict awarding past medical expenses but no general damages is inconsistent under Louisiana law and warrants a new trial | Wiltz: Awarding past medical expenses but no pain-and-suffering damages is inconsistent when medical treatment was obtained for injuries from the collision | Defendants: Jury could reasonably conclude medical care was precautionary/evaluative and that Wiltz failed to prove objective injuries caused by the collision | Affirmed: No abuse of discretion; evidence did not establish objective injuries requiring compensable pain and suffering, so the verdict was not inconsistent |
| Whether the court should amend the judgment (additur) to increase damages | Wiltz: Court should amend judgment to award additional damages | Defendants: Federal court cannot unilaterally increase jury damages; no undisputed amount justifying exception | Affirmed: Denial proper; additur is barred by Seventh Amendment except in narrow circumstances not present here |
Key Cases Cited
- Fair v. Allen, 669 F.3d 601 (5th Cir. 2012) (applicability of state law on new-trial review in diversity cases and deference to jury on quantum)
- Wainwright v. Fontenot, 774 So. 2d 70 (La. 2000) (discussing when awards of medical expenses without general damages are inconsistent)
- Matheny v. Chavez, [citation="593 F. App'x 306"] (5th Cir. 2014) (reversing denial of new trial where objective injuries necessitated medical care but jury awarded no pain-and-suffering damages)
- Dimick v. Schiedt, 293 U.S. 474 (U.S. 1935) (prohibition on federal courts increasing jury-awarded damages)
- Roman v. Western Mfg., Inc., 691 F.3d 686 (5th Cir. 2012) (limited exception to additur where liability is conceded and damages are undisputed)