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On April 9, 2013, the Missouri Supreme Court issued its decision in Badahman v. Catering St. Louis, et al. In that case, Catering St. Louis (CSL) hired the plaintiff, Sarah Badahman, as a recruiter in 2008 at an annual salary of $45,000. Her job duties required her to attend job fairs, catering events, and have reliable transportation. In July 2008, Badahman’s doctor suspended her driver’s license due her preexisting epilepsy. Badahman continued to work for CSL without her driver’s license, relying on alternative forms of transportation. Badahman eventually met with CSL president Mark Erker to discuss whether she could continue her job duties using alternative forms of transportation. At the end of the meeting, Erker terminated Badahman’s employment. Badahman was unemployed for approximately three months until she obtained another job making less money than she made at CSL.
In September 2009, Badahman filed a lawsuit against CSL, alleging the company unlawfully discriminated against her on the basis of disability and unlawfully retaliated against her. Badahman contended her damages were the difference between $45,000 a year (her projected salary at CSL) and the salary she actually received between her termination and trial – a total of $44,979.72.
After trial, the jury returned a verdict for Badahman in the amount of $11,250 for compensatory damages and $2,000 for punitive damages. Badahman subsequently filed a motion for additur (i.e., a request that the judge add additional damages to the original amount awarded by the jury). Alternatively, Badahman moved for a new trial on the issue of compensatory damages. The circuit court granted Badahman’s motion. CSL did not agree to a higher compensatory damages award. The circuit court then ordered a new trial. CSL subsequently appealed the circuit court’s grant of Badahman’s motion for a new trial. The Supreme Court concluded that the circuit court did not abuse its discretion in sustaining Badahman’s motion.
In its decision, the Supreme Court discussed at length the appropriate standard of review when faced with a challenge to a lower court’s grant of a motion for additur or – in the alternative – a new trial. First, the Court made clear when such a motion is made, and the parties elect a new trial, the Court will review a circuit court’s order under the same standard as an order for a new trial. Second, the Court made clear that a circuit court has broad discretion in ordering a new trial and that its decision will be upheld absent manifest abuse of that discretion. In reviewing the evidence, the Court will view that evidence in the light most favorable to the circuit court’s order. This is a very deferential standard and one that is difficult for challengers to overcome. Significantly, when a circuit court overrules such a motion, a reviewing court will review the evidence in the light most favorable to the jury verdict. In other words, appellate courts will tend to afford more deference to the original jury verdict.
Aside from standards of review, this case also illustrates the significance of the additur doctrine. The doctrine reflects an attempt to ensure that plaintiffs are fairly compensated for their damages. It allows a court to increase the damages award if the court finds that the jury’s award does not adequately compensate the plaintiff for her damages. As such, plaintiffs may have some recourse when a jury renders a favorable verdict that does not adequately reflect their actual damages.
If you believe your employer has violated your employment rights in the workplace, you should contact a St. Louis employment lawyer.