The plaintiff brought a negligence action for injuries from an automobile accident, with liability admitted by the defendants.
The trial proceeded on damages only before a jury.
The court addressed a dispute between counsel regarding the wording of jury questions.
The defendants proposed questions that included a causation question despite admitted liability, and sought to particularize damages by apportioning them between the initial accident and subsequent accidents.
The court rejected the defendants' proposed questions, finding them to contain embedded assumptions, to be overly complicated, and to risk confusion.
The court affirmed that admitted liability includes causation, making a separate causation question unnecessary.
It also reiterated principles against apportionment between tortious and non-tortious causes for indivisible injuries, and the general rule against requiring juries to provide reasons or particularize findings, especially for damages assessment.
The plaintiff's simpler, general damages questions were adopted.
