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Keywords

defendantnegligencetrialverdicttestimonyregulationjury instructions
damagestrialmotion

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Sanchez v. Galey, 112 Idaho 609, 733 P.2d 1234

Facts

Lorenzo Sanchez was employed by Bennett Creek Farms for about a week when he suffered a severe injury to his right hand while unclogging a potato harvester. The operator, Rusty Anderson, had not previously operated the harvester and had received limited training. Despite safety instructions to disengage the power takeoff (PTO) before unclogging, Anderson engaged the harvester while Sanchez was underneath, resulting in the injury. The jury found the defendants' negligence to be the sole proximate cause of Sanchez's injuries.

Sanchez was unfamiliar with the equipment, neither spoke nor understood English, and so could not read or understand the English safety warnings.

Issue

Whether the district court erred in ordering a remittitur or new trial without making necessary findings regarding the jury's award and whether violations of OSHA regulations constituted negligence per se.

Whether the district court was correct in its interpretation of Dinneen, supra, requiring the court to substitute its opinion on damages for that of the jury.

Rule

The court must weigh the evidence and determine if the jury's award was influenced by passion or prejudice, and violations of OSHA regulations can constitute negligence per se if they meet certain criteria.

Where a motion for a new trial is premised on inadequate or excessive damages, the trial court must weigh the evidence and then compare the jury's award to what he would have given had there been no jury.

Analysis

The Supreme Court analyzed the trial court's decision to grant remittitur and found that it failed to make necessary findings regarding whether the jury's award was shocking or unconscionable. The court emphasized that the jury's award was supported by sufficient evidence, including expert testimony on Sanchez's injuries and economic losses. The court also upheld the jury instructions regarding OSHA violations as negligence per se, affirming that the criteria for such a finding were met.

In the instant case, the trial court explained that Dinneen was the basis of its decision, despite the confusion and frustration it encountered in interpreting Dinneen.

Conclusion

The Supreme Court set aside the trial court's order for remittitur or new trial and remanded the case for the trial court to enter findings of fact regarding the jury's award. The court affirmed the jury's verdict and the instructions regarding negligence per se.

On the basis of the statements of the trial court, we cannot ascertain whether the trial court was either shocked by the jury's award, or whether it found that award unconscionable.

Who won?

Lorenzo Sanchez prevailed in the case as the Supreme Court upheld the jury's award and found that the trial court erred in its handling of the remittitur.

The Supreme Court held that: (1) trial court should not have entered order granting remittitur or new trial without entering findings of fact as to whether he was, in fact, shocked by jury award, or found award unconscionable.

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