Randall Boudreaux, M.d. v. Paula Pettaway, as Administratrix of the Estate of Paulett Pettaway Hall

Summary

The court affirmed a $4 million wrongful-death judgment against the anesthesiologist, nurse anesthetist, and their professional corporation. It held that the trial court acted within its discretion in denying a new trial based on alleged juror nondisclosures, and that the defendants failed to establish constitutional defects in vicarious liability or the punitive-damages framework. The court also held that the remitted award was not excessive and that the trial court properly considered the potential value of the defendants' insurance-related claim when evaluating financial impact. Justice Murdock, dissenting, would have rejected consideration of that hypothetical third-party recovery in assessing the punitive-damages award.