Park v. City of New York
In a personal injury action arising from a construction site accident, the Supreme Court, New York County, initially reduced a jury's award for past pain and suffering from $1,500,000 to $600,000. On appeal, the order was unanimously modified by the Appellate Division. The appellate court further directed a new trial on future pain and suffering unless the plaintiff agreed to a reduction of the award from $800,000 to $400,000. The decision was based on a comparison to similar cases involving comminuted elbow/arm fractures, multiple surgeries, and permanent limitations, while noting the plaintiff's non-dominant wrist fracture added little value as it resolved without surgery.