An Illinois truck accident case was reviewed by the Illinois Appellate Court to determine whether or not the trial court had erred in its delivery of jury instructions and whether the jury had awarded too much damages. However, after reviewing the case facts, the appellate court upheld the trial court proceedings and eventual verdict in Andrzej Chraca v. Steven Miles, 2011 Ill.App. (1st) 100537-U.
The Chraca lawsuit involved a 2004 car crash between Andrzej Chraca and Steven Miles. Chraca was driving an SUV at the time, while Miles was driving an Illinois Department of Transportation (IDOT) truck. Both Chraca and Miles suffered degrees of paralysis following the Schaumburg truck accident and both drivers filed personal injury lawsuits against each other.
The two cases were consolidated into one personal injury lawsuit by the Circuit Court of Cook County. At the end of the trial, the court ruled in favor of Chraca and against Miles. Chraca was awarded $23.8 million in damages, which was broken down as follows:
-$500,000 for disfigurement;
-$593,335 for past medical expenses;
-$3.5 million for future medical expenses;
-$2.5 million for past and future pain and suffering; and
-$18 million for past and future loss of a normal life.
And while both lawsuits were consolidated for the purposes of the Cook County personal injury trial, the appeal deals only with the lawsuit filed by Chraca.
The appeal was brought by Miles, the IDOT truck driver who was found to be 95% responsible for the Illinois truck accident. In his appeal, Miles contended that the verdict should be overturned because the trial court’s jury instructions were misleading and also because part of the jury verdict was excessive. In regards to the jury instructions, Miles alleged that the court failed to inform the jury of their four options when ruling on the case, i.e. for Chraca and against Miles, or for Miles and against Chraca, or against both Miles and Chraca, or for both Chraca and Miles. Instead, Miles argued that the jury was only instructed that it could rule for or against Chraca’s lawsuit.
Part of the basis for Miles’s appeal of the jury instructions was that the trial judge had denied to admit any of the defendants’ jury instructions. This ruling seemed to be based on language included in the defendants’ jury instructions which referred to Miles’s lawsuit as a counterclaim, a reference that the judge felt would confuse the jury as to the nature of Miles’s claim. And while one of the defendants’ jury instructions did explicitly state the four options available when deciding the case, the judge noted that these instructions were already included in one of the plaintiff’s instructions and were therefore redundant.
In its review of the trial court’s decision, the appellate court noted that “the decision to give or refuse a tendered jury instruction is within the sound discretion of the trial court…[and that] a trial court does not abuse its discretion as long as the instructions as a whole fairly, fully and comprehensively apprised the jury of the relevant legal principles.” See Schultz v. N.E. Illinois Regional Commuter R.R. Corp., 201 Ill. 2d 260, 273-274 (2002). The court held that the trial judge had appropriately instructed the jury and had not abused his discretion.
However, Miles was not only critical of the way the jury was instructed, but also of its eventual ruling. Miles contended that its $18 million award for past and future loss of a normal life was excessive and disproportionate to the rest of the verdict. Indeed, the $18 million award accounts for 75% of the total verdict amount. Miles also contended that the large award was based on evidence Chraca offered in relation to his lost wages, which was problematic because Chraca had formally removed his claim for lost wages. Miles argued that Chraca should therefore have not been allowed to enter any evidence regarding wage loss and that his doing so unfairly swayed the jury.
However, once again the appellate court disagreed. It held that “loss of normal life is a broad element or category of damage [which can include] an individual’s diminished ability to pursue and enjoy the pleasurable aspects of life and compensates for a change in the individual’s lifestyle.” Stift v. Lizzadro, 362 Ill. App. 3d 1019, 1028-29 (2005). So not only was Chraca’s testimony about his past abilities and future abilities relevant to the jury’s consideration of loss of normal life, but in no way could that testimony be considered as a form of wage loss. The court noted that the jury was never provide with any evidence regarding the plaintiff’s past salary, or his projected lost earnings. Therefore, any consideration the jury made of Chraca’s testimony was in regards to how it related to his claim of loss of normal life, not as it related to lost wages.
And as to Miles’s claim that the $18 million award was excessive, the appellate court pointed to case law which states that the “amount of a verdict is not subject to scientific computation and is generally at the discretion of the jury.” Velarde v. Illinois Central R.R. Co., 354 Ill. App. 3d 523, 540 (2004). In order for the court to overrule a jury’s verdict, the award must be so high and excessive that it shocks the court. The court was not shocked by the jury’s verdict in Chraca.
To explain their logic, the court explained that even if it “were to agree with Miles that Chraca’s activities before the collision were not extraordinary, his inability to pursue them any longer is an extraordinary limitation on his life” and therefore explains the jury’s high verdict. The appellate court pointed out that as a result of the truck accident, Chraca had suffered a spinal cord injury, paraplegia chronic pain, leg spasms, loss of bowel and bladder control, depression and sexual dysfunction. So while there is not any court required ration between economic loss and non-economic damages, the court was not shocked by the excessive nature of the jury’s verdict and therefore saw no reason to overrule it.
Kreisman Law Offices has been handling Illinois truck accident lawsuits for individuals and families for more than 35 years in and around Chicago, Cook County and surrounding areas, including Long Grove, Niles, Chicago’s Logan Square, Bridgeview, and Western Springs.
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