Stanbro v. Westchester County Health Care Corporation

Background

After a January 19, 2023 hearing concerning post-trial motions, the court instructed Chad Stanbro to submit a proposed judgment. The parties agreed to several changes but disagreed about two issues: how the judgment should describe the jury’s medical-malpractice finding and whether Stanbro should receive prejudgment interest.

Judgment Language

Westchester County Health Care Corporation and Westchester Medical Center objected to proposed language that listed them alongside Dr. Frank Weber in describing the malpractice finding. They argued that the jury had found Dr. Weber liable for medical malpractice but had not separately found them liable for malpractice. Stanbro responded that all three defendants were ultimately liable through vicarious liability, meaning responsibility for another person’s actions under the circumstances recognized by law.

The court stated that the jury found Dr. Weber liable for medical malpractice and found the two corporate defendants vicariously liable for Dr. Weber’s actions. To avoid confusion, it required the judgment to state: “Medical malpractice against Defendant Frank Weber, and through vicarious liability Defendants Westchester County Health Care Corporation and Westchester Medical Center, in the amount of $200,000.00.”

Prejudgment Interest

Stanbro requested interest on the jury’s award beginning on the date of the verdict. The defendants objected, arguing that an additional award would be punitive rather than compensatory. The court explained that prejudgment interest may compensate a plaintiff for defined losses, such as lost wages or specific medical expenses, but must not provide an overpayment.

The court found that Stanbro had not sought defined damages of that kind. Instead, the jury’s award was intended to fully compensate him for his physical injuries, pain, and suffering. The court therefore found that any prejudgment interest, including interest beginning after the verdict, would be punitive rather than compensatory. It also noted that New York law provides for post-verdict prejudgment interest in some circumstances, but that there was no similar federal provision applicable here. The court found that Stanbro was not entitled to prejudgment interest.

Disposition

Judge Kenneth M. Karas directed Stanbro to file a second amended proposed judgment by February 21, 2023. This order addressed the wording of the judgment and the request for interest; it did not alter the jury’s $200,000 award described in the order.