The Tennessee Supreme Court has reinstated a verdict against Ford which had been substantially reduced by the Court of Appeals. In Meals v. Ford Motor Company, six-year old Billy Meals was rendered a paraplegic when the Mercury Grand Marquis he was riding in was struck head-on by another vehicle. The driver of the other vehicle and Billy’s father and grandfather were killed in the tragic accident.
At the time of the accident, Billy was not properly wearing his seatbelt. Apparently, Billy was too small for the seatbelt since the shoulder portion hit him in the face. His father placed the shoulder portion of the three-point seatbelt behind Billy’s back. During the collision, Billy jackknifed over the lap portion of the seatbelt.
The seven week trial concluded with the jury finding Ford 15% at fault, the non-party driver of the bullet vehicle 70% at fault, and Billy’s father 15% at fault. Ford’s portion of the $43.8 million verdict was $6.57 million. The jury did not award punitive damages.
On appeal, Ford argued the verdict was excessive. Ford did not request a remittitur, but instead argued for a new trial. The Court of Appeals reduced the total verdict by over 70% which resulted in Ford’s portion being reduced to $1.94 million. The majority of the divided court determined the non-economic damages should be reduced to approximately double the amount of proven quantifiable economic damages.
In reinstating the jury verdict, the Supreme Court discussed the reasonableness of the jury awarding $4.3 million in economic damages and $39.5 million in non-economic damages for a six-year old with catastrophic injuries and a life expectancy of nearly 56 years. The Court also discussed how the Court of Appeals erred in its analysis of material evidence. While the Tennessee Civil Justice Act of 2011 limits non-economic damages for current catastrophic cases like this, the Meals case is a great analysis of the Court’s insight on cases not limited by the caps of the recent tort reform.