Maldonado v. Flannery

Summary

The court held that the trial court adequately explained its decision to grant additurs after the jury awarded medical expenses but no noneconomic damages. Because the credited medical treatment necessarily reflected injuries and pain, the split verdict was internally inconsistent on this record, and the trial court did not abuse its discretion in ordering additurs. The defendants’ failure to accept the additurs required a new trial limited to causation and damages.