Chronakis

The underlying litigation in this case arises from an automobile accident in which plaintiff sustained personal injuries. The matter was tried to a jury which assessed plaintiff’s comparative fault at 27 percent and awarded her $13,000 in economic damages and $25,000 in noneconomic damages. Plaintiff unsuccessfully sought a new trial based primarily on alleged juror misconduct. We agree the award of economic damages in this case was an improper quotient verdict and reverse that portion of the judgment. The award of noneconomic damages, on the other hand, appears unaffected by juror misconduct. We consequently affirm the verdict of noneconomic damages as well as the remainder of the judgment.

Facts and Proceedings Below

Plaintiff, Betty Chronakis, had worked all her life in restaurants and bars or in various sales positions. When plaintiff and her husband relocated to Arizona, they purchased and operated a restaurant/bar/motel/gas station/ trailer park enterprise on a major highway. They sold the business in the early 1980’s after plaintiff’s husband became ill and the main highway closed. Thereafter, plaintiff retired to her home in Kingman, Arizona.

In 1988, plaintiff…