Marjorie Ashmore v. Hartford Hospital

Summary

The court held that a spousal loss-of-consortium award in a wrongful death action presumptively should not be substantially greater than the noneconomic wrongful death award for the injured spouse, although evidence of an unusually unequal marriage may overcome that presumption. It also reaffirmed that remittitur decisions are reviewed for abuse of discretion, while the underlying legal question concerning the proper relationship between the awards is reviewed plenarily. Because the record did not justify the nearly four-to-one disparity and the claimed life-support trauma was not loss of consortium, the court reversed the denial of remittitur and remanded for reconsideration. No separate opinions were filed.