L. Lynne Hall v. Stanley Bergman

Summary

The court affirmed the judgment upholding the trial court’s order setting aside a general jury verdict for the plaintiff that awarded zero damages and ordering a new trial on liability and damages. Because the submitted claims required proof of actual injury, the general verdict rule required presuming that the jury found the plaintiff proved injury, making the zero-damages award insolubly ambiguous. The trial court’s consideration of the jury’s initial verdict forms was improper but harmless because the general verdict rule independently supported the new trial.