Johnson v. Pratt & Whitney Canada, Inc.

Pratt & Whitney Canada, Inc. (Pratt) appeals from a $4.9 million judgment in a wrongful death action by the heirs of two United States Marine Corps pilots killed in a helicopter crash. Pratt contends the trial court abused its discretion in refusing to grant relief from discovery sanctions, which precluded it from contesting liability or proving the comparative fault of others who may have been responsible for a proportionate share of plaintiffs’ noneconomic damages. Pratt also asserts plaintiffs were not entitled to damages exceeding $25,000, the amount prayed for in the complaint, or to prejudgment interest and expert fees awarded by the court pursuant to Code of Civil Procedure section 998. We affirm.

Factual and Procedural Background

Major Kenneth Johnson and First Lieutenant Robert Riggs died as a result of injuries they sustained when their Marine Corps helicopter crashed in Cleveland National Forest on November 14, 1986. Johnson’s wife and two children and Riggs’s parents (collectively referred to as plaintiffs) filed a lawsuit seeking damages on their own behalf and, under Probate Code section 573, on behalf of the decedents’ estates. In their first amended…