Mercado v. Ahmed

Brian Mercado (Brian), a minor, was struck by a taxi operated by Salim Ahmed (defendant). Brian’s mother, Lucy Mercado (Mercado) (plaintiff), sued Ahmed and Ahmed’s employer, the Checker Taxi Company, Inc. (Checker) (defendant), claiming that Ahmed and Checker were negligent. Mercado sought to recover damages for injuries that Brian sustained as a result of the accident, including for Brian’s loss of enjoyment of life, as Brian needed to be institutionalized or remain in a structured environment for the rest of Brian’s life. Mercado argued that Brian’s problems arose due to a head injury caused by the accident. Ahmed and Checker argued that Brian’s problems did not result from the accident, relying on evidence that Brian had a host of physical, developmental, and intellectual limitations before the accident occurred. At trial, Mercado wanted to rely on the opinions of an expert economist who calculated that the value of Brian’s loss of enjoyment of life due to the injuries sustained in the accident exceeded $2 million. The expert’s opinion was based on various research studies that examined people’s overall spending habits to avoid risks during lifetimes. The judge disallowed the expert’s opinion because the studies did not involve scientific, technical, or other specialized knowledge, and no agreement was made among economists as to how to measure the value of a person’s life. The jury ruled against Ahmed and Checker and awarded Mercado damages for Brian’s medical expenses and pain and suffering. However, the jury awarded no damages for Brian’s loss of enjoyment of life. Mercado motioned for a new trial on damages. The district court denied the motion. Mercado appealed.