A Florida court has reversed a decision that granted a new trial to Progressive Select Insurance Company in a case involving underinsured motorist benefits for Amy Marinec. This ruling affects how future cases regarding excessive jury awards may be handled in Florida courts.
The case, Amy Marinec v. Progressive Select Insurance Co., was filed in the District Court of Appeal of Florida under docket number 2D20-3351. The court's decision highlights the importance of applying the correct legal standards when determining whether to grant a new trial.
Background
Amy Marinec was injured in an automobile accident in April 2016 involving an underinsured driver. Following the accident, she filed a lawsuit against her insurance company, Progressive Select Insurance, seeking underinsured motorist benefits. Progressive admitted that the other driver was negligent but disputed the severity of Marinec's injuries.
The case proceeded to trial, where Marinec presented evidence of her injuries, medical expenses, and future prognosis. The jury ultimately ruled in her favor, awarding her $20,005.80 for past medical expenses, $405,081 for future medical expenses, $245,160 in past noneconomic damages, and $1,511,000 in future noneconomic damages.
After the jury's verdict, Progressive filed a motion for a new trial, claiming errors occurred during the trial and that the damages awarded were not supported by the evidence. They also filed a motion for remittitur, asking for a reduction in the awarded amounts. The trial court initially denied the remittitur motion but later granted Progressive's motion for a new trial, leading to Marinec's appeal.
The Ruling
The District Court of Appeal of Florida ruled that the trial court had erred in granting Progressive's motion for a new trial. The court stated, "the trial court's order reflects that its decision to grant a new trial was based on an incorrect legal standard." The judges involved in the decision were Judge Stargel, along with Judges Sleet and Atkinson, who concurred with the ruling.
The appellate court explained that the trial court had relied on the remittitur statute when it should have applied the common law standard for new trial motions. The court emphasized that Progressive's remittitur motion was denied as legally insufficient, which meant the remittitur procedure did not apply. Therefore, the trial court could not order a new trial based on the excessive nature of the jury's verdict.
Since the trial court did not apply the correct legal standard, the appellate court reversed the order granting a new trial and remanded the case for reconsideration. The court noted that the trial judge has broad discretion in determining whether to grant a new trial based on an excessive verdict.
Impact
This ruling has significant implications for future cases involving jury awards in Florida. It clarifies that trial courts must adhere to the correct legal standards when considering motions for new trials based on excessive verdicts. The appellate court's decision reinforces the idea that a trial court cannot grant a new trial simply because it finds a verdict excessive without following the proper procedures.
The ruling also emphasizes the importance of the remittitur process, which allows for a reduction in damages awarded by a jury. By clarifying the legal standards, the court aims to ensure that verdicts are respected unless there is clear evidence of error or excessiveness.
What's Next
The case has been sent back to the trial court for reconsideration under the correct legal standard. It remains to be seen whether Progressive will pursue further legal action or if there are any related cases pending.