Haacke

I. INTRODUCTION

In 2016, plaintiff and appellant Cha Haacke was hired to provide care to the

elderly mother of defendant and respondent Desrie L. Pfister. After defendant’s mother

passed, defendant made statements critical of plaintiff’s care and accused plaintiff of

causing the death of defendant’s mother. As a result, plaintiff filed a civil complaint

against defendant alleging causes of action for intentional interference with prospective

economic relations and defamation.1 In 2023, a jury returned a verdict finding that

defendant had made statements that were per se defamatory but that plaintiff had failed to

prove that the statements caused any actual injury. As a result, the jury awarded plaintiff

only presumed damages in the amount of $5,000.

Plaintiff moved for a new trial pursuant to Code of Civil Procedure2 section 657,

but the trial court denied her motion after concluding that none of the alleged errors

would have resulted in a miscarriage of justice warranting a new trial. Plaintiff appeals

from the judgment but challenges only the trial court’s denial of her motion for new trial

in her opening brief. We conclude that the record does not show an abuse of…