T&J White, LLC, d/b/a Brown Heating & Cooling ("Brown Heating & Cooling"), and its employee, Bobby Morse ("the defendants"), appealed a circuit court’s denial of their motions seeking a judgment as a matter of law ("JML") and a new trial following the entry of judgment on a jury verdict against the defendants and in favor of the plaintiff, Timothy Williams. Morse, while engaged as an employee of Brown Heating & Cooling, rear-ended Williams in a motor-vehicle collision. Thereafter, Williams filed a complaint asserting, among other things, negligence and wantonness claims against the defendants. The case proceeded to trial. After the trial court instructed the jury but before the jury retired, counsel for the parties discussed the verdict form and the jury instructions that had been given. Ultimately, the defendants requested, and received, an additional blank line on the verdict form to allow the jury to award compensatory/nominal damages with respect to the wantonness claim; this additional line was placed just before the line for an award of punitive damages. The court then read the final verdict form to the jurors, and no objections were made. The jury returned a verdict in favor of Williams, awarding the following: $500,000 in compensatory damages for negligence, $250,000 in compensatory damages for wantonness, and $750,000 in punitive damages for wantonness. After the jury was polled, defense counsel orally renewed its motion for a JML based on, among other grounds, the alleged insufficiency of the evidence of wantonness and alleged inconsistency of the verdict. The court denied the motion, concluded the trial proceedings, and entered a final judgment on the verdict. The defendants, appealing the denial of a JML on the wantonness claim and that the trial court exceeded its discretion by denying their motion for a new trial. Finding no reversible error, the Alabama Supreme Court affirmed the trial court. View "Brown Heating & Cooling v. Williams" on Justia Law
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