Sheffield v. New York City Hous. Auth

In Sheffield v. New York City Hous. Auth. (200 A.D.2d 369 [1st Dept 1994]), a personal injury action, the Appellate Division affirmed the trial court's decision in ordering a new trial on liability and damages. In Sheffield, the issue of liability was sharply contested, defendant stipulated to serious and permanent injuries and their sequelae, and plaintiff was awarded an inadequate amount for past pain and suffering and nothing for future pain and suffering. Such circumstances, the Court held, led to the ineluctable conclusion that the jurors compromised their views on liability and damages in arriving at the agreed upon award.