Pastor, Church & Law

Duplicate Verdicts

§ 10.17.02

Key point 10-17.02. Juries generally cannot assess monetary damages against two or more organizations for the same wrong. If a jury determines that a personal injury victim has suffered damages of a specified amount, it cannot assess this amount separately against more than one defendant since doing so would result in duplicate verdicts.

Juries generally cannot assess monetary damages against two or more entities for the same wrong. To illustrate, assume that a victim of sexual misconduct sues a church and a denominational agency, and that a jury determines that the victim’s damages amounted to $100,000. If the jury then assesses this amount of damages against both the church and denominational agency, it has rendered duplicate verdicts. Such verdicts are subject to reduction by the trial court or an appeals court.

Case study

  • A Colorado court addressed the liability of a church and denominational agency for a sexual relationship between a youth pastor and a girl in his youth group. The victim sued the youth pastor, her church, and a denominational agency.251 Bohrer v. DeHart, 943 P.2d 1220 (Colo. App. 1996)The jury awarded her $187,500 in compensatory damages against the youth pastor on claims of breach of fiduciary duty and outrageous conduct and another $187,500 in punitive damages. It awarded her $37,500 in compensatory damages against the church on claims of negligent hiring and supervision and breach of fiduciary duty. The jury awarded $150,000 in compensatory damages against the denominational agency on claims of negligent hiring and supervision and breach of fiduciary duty, and an additional $150,000 in punitive damages. The church and denominational agency argued that the jury’s various awards of damages were inconsistent. In particular, they argued that it was illogical to award damages against both the youth pastor and church defendants on the basis of the same theories of liability. The court agreed, noting that the jury’s award of damages against the youth pastor and church defendants for the same alleged wrongs resulted in “duplication of damages” since the actions of the church defendants did not result in any additional harm to the victim beyond what had been caused by the youth pastor.

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