Lately there has been a lot of press surrounding sensational “runaway” verdicts. That is verdicts, which are disproportionate, unreasonable, or outrageous given the factual circumstances of a case. There is not a defense attorney in the bar that does not worry about being the next recipient of a runaway verdict. This article is a part of a series of articles that will offer tips and strategies that defense attorneys should employ to combat a potential runaway verdict.

In my last article, I discussed how to mitigate runaway verdicts by taking accountability and giving the jury a specific and reasonable damages number. This article will focus on ways to deal with the largest component of runaway verdicts: noneconomic damages (“pain and suffering damages”).

How Do Plaintiffs Argue Pain and Suffering Damages?

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