Kenton v. Hyatt Hotels Corp.

693 S.W.2d 83 · Supreme Court of Missouri · 1985

Torts Assigned in 1 casebook

Case brief summary

Rule

Courts should only exclude evidence if it is irrelevant or too unfairly prejudicial. Judges should not reduce a jury's damages award just because they disagree with the amount.

Facts

Kay Kenton, a law student, was severely and permanently injured when walkways collapsed in a Kansas City hotel lobby in 1981. A jury awarded her four million dollars for her losses.

Procedural history

The trial judge thought the verdict was too high and cut it by 250 thousand dollars. Kenton agreed, the hotel appealed, and the Missouri Supreme Court took the case directly.

Issue

Did the trial court make legal errors in letting in certain evidence and expert testimony and in limiting jury questioning, and was the trial court right to reduce the jury's four million dollar award by 250 thousand dollars?

Holding

The Missouri Supreme Court upheld the trial court on all the evidence and trial conduct issues but reversed the reduction of the verdict, ordering that the full four million dollar jury award be reinstated.

Reasoning

The court said evidence about the accident scene, Kenton's background, and her career prospects was properly allowed. It also ruled judges could no longer reduce jury damage awards in Missouri.

Opinions

Majority (Dowd): Upheld all the trial court's evidence rulings and expert testimony decisions, but reinstated the full four million dollar verdict because remittitur is no longer permitted.

Dissent (Welliver): Disagreed with the majority's decision, though the opinion does not explain his specific reasons.

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What structure collapsed, injuring the plaintiff Kay Kenton?

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What happened to Kay Kenton on July 17, 1981, and where?
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