Seffert v. Los Angeles Transit Lines
Citation and Court
56 Cal. 2d 498 (1961), Supreme Court of California
Facts
Seffert’s foot was caught in the doors of a bus operated by Los Angeles Transit Lines and she was dragged a considerable distance, suffering severe and permanent injuries to her foot and leg. The jury awarded $187,903.75 in damages, including substantial sums for past and future pain and suffering. The defendant argued the award was excessive.
Issue
Whether the jury’s large pain and suffering award was so excessive as to require reduction by the court.
Holding
The California Supreme Court affirmed the jury’s award, finding it was not so disproportionate to the injuries as to suggest passion or prejudice on the jury’s part. Justice Traynor dissented, arguing the award was excessive.
Rule / Doctrine
Pain and suffering damages are inherently difficult to quantify and are committed largely to jury discretion. A reviewing court will not reduce a pain and suffering award merely because it seems large; the award will be disturbed only if it is so grossly disproportionate to the injury as to shock the conscience or suggest passion, prejudice, or corruption by the jury.
Significance
Seffert is a canonical case on the review of pain and suffering damages. The majority and Justice Traynor’s dissent together illuminate the tension between deference to jury verdicts in damages cases and the concern that large noneconomic awards are unreviewable and potentially arbitrary. It is often used to discuss whether pain and suffering awards can or should be more systematically constrained.