Our firm was asked to defend a trucking company the month before the trial in an admitted liability case in southern Illinois. The plaintiff asked for $996,905.00 from the jury in closing argument. She was a 46 year old woman who underwent an arthroscopic knee surgery and a rotator cuff repair that left her unable to raise her right arm. She also claimed aggravation of pre-existing conditions for back pain, neck pain and fibromyalgia. Lastly, her medical experts claimed permanent memory loss, future knee replacement and permanent pain management. She claimed $143,508.00 in medical specials.
During closing argument, King Roy suggested the jury award $50,000.00 for past and future pain/suffering and loss of normal life. The jury agreed, and only awarded $50,000.00 for all non-economic damages. The jurors also agreed with our proposed numbers for the medical treatment. After deliberating for 30 minutes, the jury returned with the verdict that we recommended: $141,343.71. This was nearly $75,000.00 less than the last offer and over $600,000 less than plaintiff’s last demand.