Paul Caldwell, Plaintiff-Respondent v. Deloris Haynes, Defendant, and Todd Kehler and Alice S. Kehler…

Summary

The Supreme Court of New Jersey reversed the Appellate Division’s judgment and remanded for a new trial on all damages, holding that the jury’s awards for past and future lost earnings and pain and suffering were excessive. The Court also held that plaintiffs bear the burden of proving net income in personal‑injury actions and that juries must be instructed on work‑life expectancy and present‑value calculations.