In Donlon v. City of New York, 284 A.D.2d 13 [1st Dept 2001], a panel majority adopted a methodology that "evaluates whether the appealed award deviates materially from comparable awards," and that "involves identification of relevant factual similarities and the application of reasonable judgment." (Id. at 15.) Although recognizing that "reasonable compensation" has also been understood to require a review of "record evidence," the panel opted for "case comparison reasonableness," in which "analogous cases will be useful as benchmarks." (Id. at 16.) The majority in Donlon appears to limit the review of record evidence to "whether or not the verdict is supported by the evidence," (id. at 18) , an inquiry quite different from the "weight of the evidence" standard, and one that is used when a party is asking for judgment, rather than a new trial, see Nicastro v. Park, supra, 132-33, 135. The alternative inquiry, "explicitly mandated by CPLR 5501(c)...requires [the court] to determine what awards have been previously approved on appellate review and decide whether the instant award falls within those boundaries." (Donlon, supra, at 18.) There was a strong dissent by Justice Mazzarelli: "Modification of damages, which is a speculative endeavor, cannot be based upon case precedent alone, because comparison of injuries in different cases is virtually impossible ... Comparison of cases is an even more tenuous endeavor for an appellate court because we are constrained to rely on what are often scant summary factual recitations in prior decisions." (Donlon, supra, at 21) (Mazzarelli, J., dissenting). For example, "the awards in ... cases should be discounted to reflect the years which have passed since those decisions were rendered." (Id. at 22.)