Published: Jun 13, 2026
When an insurance company tries to shrink a jury's payout and ends up with the full bill instead, the legal missteps behind that outcome are worth understanding.
An Ohio appeals court has reinstated a $203,806 jury award against State Farm, ruling that the insurer's post-verdict legal maneuvers were procedurally defective, according to Insurance Business. The case centered on a policyholder hit by uninsured drivers who then sought compensation through her own uninsured motorist coverage. As Insurance Business reported, State Farm's attempt to use standard post-verdict motions collapsed because the trial court applied them incorrectly. The State Farm uninsured motorist verdict is now a clear reminder that procedural rules cut both ways.
State Farm's appeal backfires as Ohio court restores $203,806 award
State Farm went into the Ohio appellate process expecting to defend a dramatically reduced award. It came out owing the full jury verdict.
The appeals court did not reverse the lower court on the facts. It reversed on procedure. The trial court had cut economic damages from $163,806 down to just $6,831, and non-economic damages from $40,000 to $2,000. The panel found that neither reduction was legally authorized under the motions the carrier had actually filed.
The court called the trial court's judgment "void" because it granted "no relief authorized under law." That is a significant phrase. It means the lower court did not merely err in its reasoning; it issued an order it had no power to issue in that form.
The result: every dollar the jury originally awarded was reinstated.
From a 2016 crash to a decade-long legal fight
The story starts with a car crash in 2016. Terry Benetis was struck by drivers who carried no auto insurance. Because the at-fault drivers had no coverage, she turned to her own State Farm policy's uninsured motorist provision.
The uninsured drivers defaulted, leaving State Farm as the sole defendant at trial.
On September 27, 2024, a jury sided with Benetis and awarded her $203,806. That total broke down into $163,806 for past medical and economic losses, and $40,000 in non-economic damages. Nearly a decade had passed since the crash before that verdict came in.
If you live in Ohio and carry UM coverage, understanding your policy's terms before a dispute escalates is critical. See what Ohio drivers typically pay for auto insurance to understand whether your current policy limits are competitive for your situation.
How the trial court slashed the award, and why that move was ruled void
State Farm asked the trial court to override the jury using two distinct legal tools: a motion for judgment notwithstanding the verdict (JNOV), and a request for remittitur, which is a court-ordered reduction of a jury award.
A magistrate agreed with State Farm's core argument that Benetis had not sufficiently proven causation. The magistrate cut economic damages to $6,831 and non-economic damages to $2,000. The trial court adopted that ruling on September 15, 2025.
The appeals court found this approach fatally flawed on multiple grounds.
A JNOV requires the court to enter judgment for the party requesting it. Instead, the court issued a modified award for Benetis herself, which is not what a JNOV allows. Remittitur carries its own procedural checklist, none of which was followed. The result was an order that did not fit any recognized post-verdict remedy.
The two legal tools State Farm misused: JNOV and remittitur
Understanding why the ruling collapsed requires knowing what each motion actually demands.
| **JNOV (Judgment Notwithstanding the Verdict)** | Court enters judgment for the party that requested it | Court reduced the award for Benetis instead |
| **Remittitur** | Judge must find verdict excessive but not driven by passion or prejudice; plaintiff must consent or court must offer a new trial | Court did neither step |
The trial court's order did not satisfy either standard. It was not a valid JNOV because judgment went to the wrong party. It was not a valid remittitur because the required findings were never made and Benetis was never given the option of a new trial.
State Farm's attorneys may have filed the right motions on paper. The problem was the court applying them in a way that corresponded to neither one.
The court called the trial judgment "void" because it granted "no relief authorized under law."
That language from the appellate panel is unusually sharp. It signals that this was not a close call on appeal.
Why the psychologist's testimony proved decisive
State Farm's core causation argument rested on the claim that Benetis's medical experts never connected her treatment to the 2016 crash. The carrier pointed out that her only documented 2016 treatment involved "soft tissue" injuries relating to chest pain and contusion.
The trial court appeared to agree, suggesting that a psychologist Benetis retained to evaluate her had failed to link the treatment to the accident.
The appeals court read the record differently.
The psychologist testified that the accident was the "direct and proximate cause" of Benetis's PTSD, major depressive disorder, and panic disorder.
That testimony directly contradicted the lower court's characterization. The appeals panel found the trial court had not simply assessed the evidence; it had weighed the credibility of an expert witness. Credibility determinations belong to the jury, not the judge. By second-guessing a witness the jury had already evaluated, the trial court crossed a line it was not permitted to cross.
The lesson for insurers challenging expert testimony: if the expert actually testified to causation, disputing that on post-verdict motions is a difficult position to sustain.
What this means for you
If you were injured by an uninsured driver and your own carrier disputes causation, document every medical appointment and ensure your treating providers explicitly connect your diagnosis to the accident in their records and testimony. Review your uninsured motorist coverage limits now, before a claim arises. The Save Max Quote Index, drawn from 3.3 million+ real quote requests, consistently shows that policyholders who compare UM coverage options at renewal secure meaningfully higher limits for comparable premiums. If your jury award is challenged, understand that post-verdict motions have strict procedural requirements that courts must follow; a ruling that skips required steps can be reversed. Drivers in neighboring states such as Indiana and Kentucky face similar uninsured motorist exposure and should verify their UM limits reflect current road risk in their area.
Key takeaways from the ruling
What the Ohio appellate decision establishes for policyholders and insurers alike:
- A jury award can survive a post-verdict challenge if the insurer or trial court fails to follow the specific procedural steps each motion requires.
- JNOV and remittitur are distinct legal instruments with distinct requirements; conflating them or skipping required steps renders the resulting order void.
- Judges cannot substitute their own view of expert credibility for the jury's; that determination belongs to the people in the jury box.
- Expert testimony explicitly linking an accident to a diagnosis carries significant weight; an insurer's claim that such testimony was absent can be undone by the trial record itself.
- Uninsured motorist coverage is only as valuable as the limits you carry; a successful verdict means nothing if the underlying policy limits are too low to cover your actual losses.
- Per the SMQI, policyholders who review UM coverage at each renewal are better positioned to avoid coverage gaps when a claim reaches the litigation stage.
FAQ
What is uninsured motorist coverage and why does it matter in this case?
Uninsured motorist (UM) coverage pays for your injuries when a driver who caused your accident has no liability insurance. In the Benetis case, the at-fault drivers carried no coverage at all, which meant her only path to compensation was through her own State Farm UM policy. Without that coverage, she would have had no insurer to pursue.
Can an insurance company reduce a jury verdict after trial?
Yes, but only through specific legal mechanisms with strict procedural requirements. A JNOV requires judgment for the requesting party, while remittitur requires the judge to find the verdict excessive and either obtain the plaintiff's consent or offer a new trial. The Ohio trial court followed neither process correctly, which is why the appeals court reversed the reduction.
What is PTSD's role in a car accident insurance claim?
Psychological injuries such as PTSD, major depressive disorder, and panic disorder can be compensable in a personal injury or UM claim if a qualified expert testifies that the accident was the direct and proximate cause of those conditions. In this case, the psychologist's testimony to exactly that point was central to the appeals court's decision to reinstate the full verdict.
What should I do if my insurer disputes causation after a crash?
Ensure every medical and mental health provider you see documents the connection between the accident and your symptoms in writing. Ask providers directly whether they will be able to testify about causation if the case goes to trial. Gaps in that documentation are the primary argument insurers use to challenge damage awards. Drivers across states like Pennsylvania and Michigan face similar causation disputes in UM litigation.
How do I know if my UM coverage limits are adequate?
Review your declarations page and compare your UM limits against the medical costs a serious injury could realistically generate. The Benetis verdict alone totaled over $200,000. Many standard policies carry UM limits well below that threshold. Comparing quotes at renewal is the most direct way to assess whether higher limits are available at a price that fits your budget.
About Brooke Grissom
Brooke Grissom is an Independent Insurance Analyst at SaveMaxAuto, licensed in Property & Casualty and Health insurance. She covers data-driven market trends, cross-state premium comparisons, and carrier financial analysis. Read more from Brooke Grissom →
Edited by Cassidy Richey.
Methodology
This article is grounded in the source linked above. SaveMaxAuto data points referenced here are drawn from the Save Max Quote Index (SMQI), a proprietary instrument reflecting 3,364,317 real consumer quote requests submitted to savemaxauto.com. State and carrier rankings reflect the lifetime dataset; year-over-year shifts reflect a rolling 12-month window. The index is refreshed monthly. External authority figures referenced (NAIC, NHTSA, state regulators) reflect the most recent public data releases available at time of writing.
Sources
- Primary source: Insurance Business, "State Farm loses appeal as court reinstates $203,806 crash verdict"