The essential elements of a cause of action in negligence are well established: duty; breach of that duty; causation; and actual injury. Without proof of each of these elements, a plaintiff's cause fails entirely, and he is not entitled to have the question of damages considered. This is because conduct that is merely negligent, without proof of an actual injury, is not considered to be a significant interference with the public interest such that there is any right to complain of it, or to be free from it.
An injured party sued defendant motorist in the trial court for negligence resulting in an automobile accident. After a jury awarded no damages, the trial court set aside the verdict and granted a motion for additur. The trial court awarded the injured party nominal damages. On appeal, the award was affirmed. The motorist appealed to the Supreme Court of Connecticut.
Was the injured party entitled to nominal damages?
The Supreme Court held the injured party was not entitled to nominal damages based on the motorist's admission of liability. Prior authority holding the motorist's admission showed the injured party suffered a technical legal injury and was, thus, entitled to at least nominal damages was expressly overruled. The injured party had to prove all elements of a negligence claim, including causation and actual injury, to recover, so the technical legal injury concept did not apply to a negligence action. Nominal damages were recoverable when a plaintiff's right was intentionally invaded, but a negligence case required proof of causation and actual damages. Without proof of the essential elements of duty, breach of that duty, causation, and actual injury, the injured party's negligence claim failed, and he was not entitled to have the issue of damages considered. Conduct that was merely negligent, without proof of actual injury, was not a significant interference with the public interest such that there was a right to complain of it or be free from it.