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Mader, S. v. Duquesne Light

Citation: 199 A.3d 1258Docket: 609 WDA 2018

Court: Superior Court of Pennsylvania; November 30, 2018; Pennsylvania; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves a post-trial appeal by Duquesne Light Company challenging the order granting Steven Mader a new trial on damages after sustaining severe injuries from contacting a high-voltage power line. Mader, a masonry contractor, suffered critical burns and amputations, leading to a lawsuit claiming negligence by Duquesne for maintaining low power lines. The jury found Duquesne 60% negligent, awarding Mader $500,000 in compensatory damages but denied punitive damages. The trial court granted a new trial limited to damages, which Duquesne contested. The appellate court partially reversed the trial court's decision, upholding the jury's original award for past medical expenses and determining the trial court abused its discretion in granting a new trial on this issue. However, the appellate court upheld the trial court's decision to grant a new trial on damages for lost earnings and pain and suffering, given the evidence of chronic pain and the impact of injuries on Mader's earning capacity. The case has been remanded for further proceedings consistent with these findings.

Legal Issues Addressed

Jury Verdicts and Appellate Review

Application: The appellate court found the jury's award for past medical expenses was supported by evidence, reversing the trial court's grant of a new trial on those grounds.

Reasoning: The appellate court found that the jury's award of $444,525.56 for past medical expenses was adequately supported by the evidence.

Lost Wages and Earning Capacity

Application: The trial court granted a new trial for lost earnings based on evidence that Mader's injuries caused a significant decline in his earnings, which was upheld by the appellate court.

Reasoning: Mader’s earnings significantly declined post-accident, evidencing the impact of his injuries on his earning capacity.

New Trial Standards and Discretion of Trial Courts

Application: The trial court granted a new trial on damages, which was partially reversed by the appellate court, emphasizing that a trial court's discretion in granting new trials is broad but subject to reversal if abused.

Reasoning: A new trial serves as an essential mechanism to correct injustices resulting from errors or unfairness in the original trial, aiming to achieve a just outcome.

Pain and Suffering Damages

Application: The appellate court upheld the trial court's decision to grant a new trial for damages related to pain and suffering due to evidence of chronic pain from permanent injuries.

Reasoning: The trial court had reasonable grounds to grant a new trial on damages for pain and suffering, embarrassment, humiliation, and loss of enjoyment of life, particularly given Mader's significant and permanent injuries.

Stipulations and Jury Instructions

Application: The jury followed the court's instruction to award the stipulated amount for past medical expenses, and the appellate court held this did not warrant a new trial.

Reasoning: Stipulations are binding on both the court and the parties, and juries are presumed to follow court instructions.