Elliott Riches

Anderson v. Sears
Facts: Facts. The Plaintiff, Helen Britian (Plaintiff), was severely burned as a young
child when her home was destroyed by a fire. The blaze was caused by a heater
negligently manufactured by the Defendants, Sears and Controls Company of
America (Defendants). The jury awarded plaintiff $2,000,000 in compensatory
damages. Defendants moved for remittitur.
Issue: Was the trial court correct in determining that the verdict of the jury did not
exceed the maximum amount which the jury could reasonably find based on the
maximum recovery rule?
Holding: Yes
Reasoning: The maximum recovery rule is intended to protect the role of the jury as
finder of facts. Judges must determine only the maximum award that the jury could
reasonably have reached, based on all of the evidence as to each element of
damages. In the present case, five elements of damages are applicable: (i) past
physical and mental pain; (ii) future physical and mental pain; (iii) future medical
expenses; (iv) loss of earning capacity and permanent disability and (v)
disfigurement. This Court examines each of these elements individually,
determining the maximum amount of damages available under each based on the
evidence available. Considering each of these elements in unison, this Court
determines that the maximum jury award supported by the evidence is $2,980,000.
Therefore, the jurys damage award is valid.