The Tennessee Supreme Court has reinstated a Shelby County jury’s verdict awarding damages for the injuries a six-year-old boy sustained in a car wreck.
In January of 2002, Billy Meals was riding with his father and grandfather in his grandfather’s car. Billy was in the backseat restrained with a lap belt, while the shoulder belt was tucked behind his body because it did not fit properly. Another vehicle driven at a high rate of speed and operated by a person under the influence of alcohol and cocaine struck the Meals vehicle head on.
Billy’s father and grandfather were killed. Billy survived, but sustained serious and life-changing injuries when his lap belt was propelled into his stomach, damaging his spine and internal organs. Billy became paralyzed from the waist down and could no longer perform basic functions of daily living without substantial assistance and accommodation. He required extensive medical care, including numerous surgeries and physical therapy and continues to experience medical difficulties as a result of the injuries he sustained in the wreck. It is expected he will face complications throughout the rest of his life.
In 2003, Billy’s mother filed suit on his behalf against several defendants, including the maker of his grandfather’s car, Ford Motor Company, alleging that the defective design of the seatbelt and Ford’s failure to warn of the danger caused Billy’s permanent paralysis and other injuries. The jury heard proof that Billy’s past and future medical bills and lost wages were calculated to be $4.3 million; that Billy will never walk again; and that he will suffer the effects of his injuries for the rest of his life.
A Shelby County jury returned a verdict of $43.8 million in damages, finding Ford to be 15 percent at fault, liable for $6,570,000 of the total. Ford appealed, and the Court of Appeals suggested reducing the total verdict amount from $43.8 million to $12.9 million, which would have reduced Ford’s responsibility to $1,935,000. The Court of Appeals concluded that the jury’s award of non-economic damages of $39.5 million showed sympathy and was excessive.
In a unanimous opinion, the Tennessee Supreme Court held today that the Court of Appeals applied incorrect reasoning when it concluded that the jury’s verdict was excessive. The Court engaged in its own review of the proof and concluded that the jury’s verdict was supported by evidence and was within the range of reasonableness. The Court explained that an appellate court’s review of a jury’s verdict is limited to determining whether there is material evidence to support the verdict. If there is any such evidence, the appellate court must affirm the verdict.
Accordingly, the Tennessee Supreme Court reversed the judgment of the Court of Appeals and reinstated the jury’s verdict requiring Ford to pay $6,570,000 in damages.
Read the unanimous Opinion in Aundrey Meals ex rel. William Meals v. Ford Motor Company, authored by Justice Sharon G. Lee.