Court overturns jury verdict for fired employee; limits compensation to past economic damages despite apparent jury confusion
In Larry v. Hurley Medical Center, the plaintiff sued the employer hospital arguing that it violated the Whistleblower Protection Act when it fired her in violation of the Civil Rights Act. She had also alleged that her firing was inappropriate because the hospital lacked "just cause" under their contract.
The jury agreed and executed a verdict form that awarded her $56,000.00 in past economic damages. It also awarded her non-economic damages, which were not collectible if the firing was a contract violation but not a WPA or CRA violation. The jury did not initially award any future economic damages. The Court expressed concern that the jurors misunderstood the verdict form and caused them to return to deliberations, after which the jury awarded $83,577 in future economic damages and eliminated the non-economic damage award.
The defendant appealed and the Court of Appeals struck down the judgment, holding that since the questions on the verdict form were "clear and unambiguous" the judge abused his discretion in asking the jurors to clarify their original award. The past economic award was enforced but no other damages were awarded, either for non-economic loss or for future economic loss.