In Badahman v. Catering St. Louis, Inc., a case argued by Gregory Rich, the Missouri Supreme Court found that a trial court did not abuse its discretion when it ordered a new trial on damages for a woman who alleged that she was discharged because of her disability. In its decision, the Supreme Court clarified the standard of review that appellate courts are to use when reviewing a trial court’s discretionary decision to order a new trial on the ground that the verdict is against the weight of the evidence.
In April 2011, Sarah Badahman prevailed at trial against Catering St. Louis on her claim of disability discrimination in violation of the Missouri Human Rights Act. Although it returned a unanimous verdict in her favor, the jury awarded Ms. Badahman only a fraction of her actual lost wages. Ms. Badahman then asked the trial court to grant her additur (an increase in the amount of the jury’s award) or a new trial on the issue of damages because the jury’s award of damages was inconsistent with the evidence presented at trial. The trial court agreed with Ms. Badahman and ordered a new trial on the issue of damages.
After Catering St. Louis appealed the trial court’s order, the Missouri Court of Appeals reviewed the evidence in the light most favorable to the jury’s verdict and found that the trial court abused its discretion in granting Ms. Badahman’s request for a new trial because there was a reasonable basis for the jury’s award of damages. The Court of Appeals then reinstated the jury’s verdict.
Recognizing that there was some confusion among Missouri’s appellate courts regarding the proper standard of review, the Missouri Supreme Court attempted to eliminate the confusion by holding that in cases where a trial court has ruled on a motion for additur, remittitur, or a new trial, appellate courts must review the evidence in “the light most favorable to the circuit court’s order.” Based upon this standard of review, the Supreme Court found that the trial court was within its discretion to grant Ms. Badahman’s request for a new trial on the issue of damages and affirmed the trial court’s decision.