ATLANTA, Ga. — The Georgia Supreme Court has overturned a $1 million jury award to a woman who alleged she suffered an injury while shopping at a Walmart in Conyers. The court concluded that the significant sum awarded did not align with established standards for nominal damages.
In a ruling issued on Tuesday, the court directed lower courts to determine whether the jury’s decision in Bettie Leverette’s case should be annulled. Leverette had claimed that her injuries resulted from the negligence of Walmart employees, leading to diagnoses that included mild traumatic brain injury and post-concussion syndrome.
Walmart contested Leverette’s claims, arguing that her health issues were primarily due to pre-existing conditions rather than any incident in their store. Despite these defenses, the Gwinnett County jury sided with Leverette and granted her $1 million in nominal damages, opting not to specify any additional categories for past or future pain and suffering or care expenses.
After the jury’s decision, Walmart sought a new trial. However, two lower courts denied this request, referencing prior rulings that permitted substantial awards for nominal damages. The issues were brought before the state’s highest court on March 18, 2025.
The Supreme Court’s unanimous opinion, delivered by Justice Andrew A. Pinson, highlighted the historical context of nominal damages, which are traditionally viewed as small sums awarded when plaintiffs establish legal violations without proving actual harm. The court emphasized that $1 million does not constitute a trivial amount, which is the expected range for such damages.
Pinson noted, “No rational juror could conclude that $1 million meets that description,” pointing out that prior cases with far lower amounts were deemed excessive. The ruling underscored the notion that compensation is intended to reflect a violation without substantial harm, thereby reinforcing limits on how nominal damages are awarded.
The Georgia court’s decision could have significant implications for similar cases, particularly in establishing clearer boundaries for jury awards that may otherwise be perceived as inflated.
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