Marjorie Ashmore v. Hartford Hospital

Summary

The court held that appellate review of a trial court's decision on a remittitur motion remains deferential abuse-of-discretion review, although the legal question underlying the remittitur decision is reviewed plenarily. It adopted a presumption that a loss-of-consortium award in a wrongful-death action should not be substantially greater than the directly injured spouse's noneconomic wrongful-death award absent evidence explaining the disparity, and held that the record did not justify the disparity here. The judgment denying remittitur was reversed and the matter remanded for reconsideration under that framework.