Pennsylvania Court Holds Jury is Free to Disbelieve Car Accident Victim’s Alleged Pain and Suffering
In a recent case before the Pennsylvania Superior Court, the issue was whether the jury had properly weighed the evidence in granting its award for damages to a motor vehicle accident victim. After reviewing the record before the trial court, the appellate court stated the rule that a jury is not required to award a plaintiff damages if it believes that the plaintiff did not suffer harm.
The facts of this case involve a motor vehicle accident in which Joyce Brody rear-ended Mica Wilson. Ms. Wilson sought and received medical treatment for her injuries. She then brought a lawsuit against Ms. Brody for damages. At trial, Ms. Brody conceded her liability, and Ms. Wilson offered testimony concerning her injuries. The issue before the jury was the extent of Ms. Wilson’s pain and suffering.
Initially, the jury returned a verdict of no damages. After further review, they returned a verdict in favor of Ms. Wilson and assessed damages for $500.00. Ms. Wilson moved for a new trial, for additur, and for delay damages, but both motions were denied. Ms. Wilson appealed.
The appellate court stated that their standard of review is limited to determining whether the trial court abused its direction. They must ask whether a new trial would produce a different verdict. The court also stated that when their review stems from a challenge to a jury’s determination of damages, their review is “highly circumspect.”
While Ms. Wilson claimed that the jury award of $500 did not have a relationship to the evidence offered at trial, Ms. Brody stated that the jury was free to disbelieve Ms. Wilson’s evidence and award as much or as little as it deemed appropriate. The court stated the rule that when a jury awards medical expenses without compensation for pain and suffering, that award should not be disturbed if the trial court may have believed that the jury did not believe the plaintiff suffered harm or that a preexisting condition solely caused the pain and suffering. The court stated the rule that a jury is free to believe all, part, or none of the evidence presented at trial.
Expert testimony included Ms. Wilson’s treating physician, who testified that after the accident, Ms. Wilson suffered from a sprain in her cervical spine. Ms. Wilson also testified that she continued to suffer pain a few times a week as of the time of the trial. But on cross-examination, Ms. Wilson testified that she did not have any injuries at the time of the accident.
The appellate court reviewed Ms. Wilson’s trial testimony, including her statements that after the accident, she was able to lift the back gate of the SUV she had been operating, and she also told the police on the scene that she did not need an ambulance. Ms. Brody introduced the testimony of an orthopedic doctor who stated that after reviewing Ms. Wilson’s records, it seemed that she had unresolved issues of pain from her cervical spine that predated the motor vehicle accident.
The appellate court concluded Ms. Wilson was not entitled to relief. The jury had heard the evidence and was free to disregard Ms. Wilson’s medical testimony, and it was also free to conclude that the accident resulted in $500 of damages for pain and suffering. In addition, the jury could weigh the testimony and conclude that Ms. Wilson’s complaints stemmed from prior injuries. The court stated they cannot substitute their judgment for that of the jury.
The appellate court affirmed the judgment.
Personal injury lawsuits involve issues of credibility, particularly regarding evidence and proving fault. At Needle Law Firm, our personal injury attorneys can help you seek the compensation you deserve and provide guidance on your legal options. For a free consultation, call today at 570-344-1266.