Massachusetts Appellate Court Reverses Zero Damages Award in Car Accident Case

In the recent case of Rose v. Farina, a Massachusetts Court of Appeals was presented with the question of whether a jury was inconsistent in the way that it answered three targeted questions presented to them in a motor vehicle accident case. The facts of the case are as follows. During 2007, the plaintiff and the defendant were involved in a car accident resulting in severe injuries to the plaintiff. In his lawsuit, the plaintiff contended that the defendant was at fault for the accident and responsible for his injuries. During the trial, the defendant offered evidence indicating that the plaintiff’s injuries were preexisting and not a result of the car accident. The trial also included expert witness testimony regarding the plaintiff’s injuries.

At the close of trial, the jury was tasked with addressing three specific questions:  do you find the defendant negligent, was the defendant’s negligence the proximate cause of the plaintiff’s injuries, and how much money would adequately and fairly compensate the plaintiff for the injuries and damages he sustained due to the defendant’s negligence.

The jury answered the first and second questions “yes,” but it awarded zero dollars in response to the third question. The plaintiff objected, asking the judge to provide the jury with new instructions regarding the amount of damages awarded and to task the jury with additional deliberations on this point. The judge denied the plaintiff’s request and instead dismissed the jury. Although the plaintiff filed a motion for additur, which asks the judge to increase the damages award, and a motion for a new trial, the judge denied these as well.

The plaintiff appealed the outcome to the appellate court, which ultimately agreed with the plaintiff that the jury’s responses to the three questions were inconsistent. Although the jury found the defendant to have been negligent and concluded that the defendant’s negligence was the proximate cause of the plaintiff’s injuries, the jury awarded the plaintiff no recovery. Nothing at trial suggested that the plaintiff was contributorily negligent for the harm he incurred. Instead, the defendant only presented evidence that the injuries the plaintiff claimed to have suffered were already existing at the time of the accident. Accordingly, the record did not support any implied findings that the plaintiff’s injuries, regardless of when he incurred them, failed to result in damages to the plaintiff.

According to Massachusetts Civil Procedure law, the court was unable to reassemble the jury for the purpose of reconsidering the issue and instead vacated the judgement and remanded the matter for a new trial.

If you or someone you know has suffered injuries in a car accident, you may be entitled to compensation. Understanding the scope of your injuries and how they affect your ability to recover monetary compensation is a critical part of planning your case and collecting evidence. One of the first steps you should take after the accident is obtaining medical care to assess your condition and begin a record of your treatment. At The Law Offices of John S. Moffa, our car accident legal professionals have provided dedicated and aggressive representation to car accident victims throughout Massachusetts. Call us now at 1-866-476-0828 or contact us online to set up your free consultation today.

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