Creamer v. Troiano
In Creamer v. Troiano, 108 Ariz. 573, 575, 503 P.2d 794, 796 (1972), Chief Justice Hays explained the test for reviewing a trial court's ruling on additur, remittitur, and new trial because of an inadequate or excessive verdict as follows:
From what we have written, it is obvious that the test for reviewing the granting or refusing of a trial judge's adjustment of a verdict is complex and can only be solved by an ad hoc approach.
Almost always when there is a conflict in the evidence, the trial judge should not interfere with what is peculiarly the jury's function, and if he does not, we will nearly always uphold him.
If there is no conflict in the evidence on items that obviously were omitted from the verdict, the trial judge must adjust, and we will uphold him if he does. Behind all of these tests still stands the original doctrine - that if the verdict is supported by adequate evidence, it will not be disturbed, and the greatest possible discretion is in the hands of the trial judge.
In this court, the ultimate test will always be justice, and any case before us which shows an unjust result because of the granting or denial of either additur or remittitur, will be reversed. Each case will be considered upon its own facts. Id. at 576-77, 503 P.2d at 797-98.