Is it possible for a court to adjust damages awards upward beyond what is asked for?

Question

When a plaintiff (or counter-claimant) has only sought $1 in relief, do courts ever adjust that upward to reflect the true value of damages?

Answer 1

I don't know of any cases where a court has done this, but the law would permit it in an appropriate circumstance.

Under Fed. R. Civ. P. 54(c) federal courts in the united-states may grant relief beyond what the complaint demands:

Final judgment should grant the relief to which each party is entitled, even if the party has not demanded that relief in its pleadings.

The same is true in new-york under N.Y. C.P.L.R. Law § 3017:

The court may grant any type of relief within its jurisdiction appropriate to the proof whether or not demanded.

Answer 2

In france, the court is bound by the parties’ claims. See articles 4 and 5 du code de procédure civile:

L'objet du litige est déterminé par les prétentions respectives des parties. (...) Le juge doit se prononcer sur tout ce qui est demandé et seulement sur ce qui est demandé.

The dispute is determined by the claims of all parties. (...) The judge must rule on all which is asked, and only that which is asked.

Say I borrow your car, I return it with a broken window, and we end up at trial.

You claim that (1) you had to pay a mechanic €500 to fix the window and (2) you underwent significant emotional distress when seeing the broken window, worth €1 million. I claim that the window was already damaged when I borrowed the car, so I should not be held liable for anything; furthermore, in any case, the window could have been fixed for €100, and you did not have any significant emotional damage worth paying for.

The judge must rule within the bounds of your claims (1) and (2) (in that example I have not put forward any counterclaim). All the following would be grounds for a successful appeal:

• the judge rules I owe you €250 for the broken window, and does not say anything about emotional distress. Or alternatively, that €1m for emotional damages is absolutely ridiculous and dismisses the case without saying anything about the repair cost. That would be infra petita (ruling on less than what was asked); each claim must be addressed separately (if only to say, "and because of the same reasoning, claims 2, 7 and 11 also fail").
• the judge rules I owe you €1000 for the broken window, and nothing for emotional distress. That would be ultra petita: they cannot give you more than what you asked for each item (even if the combined result is within the claim).
• the judge rules I owe you €300 for the broken window, nothing for emotional distress, and €200 in lost wages for the day you missed work due to having to fix the car. That would be extra petita: they cannot rule on anything that was not raised specifically by the parties (again, even if it fits within the "global envelope" of the claims).

I have never seen a general claim "for any relief that would be just and proper" (or similar). I suspect such a claim would be dismissed, but could not quickly find any case law on the subject. I would say it violates a combination of article 4 and article 6 - you must make specific claims and bring proof to establish each claim.

Answer 3

united-states

Yes, it is possible for the jury to award more than is asked for, whether it was one dollar or another value.

In fact, in Bollea v. Gawker, the plaintiff asked for $100 million. The jury awarded $115 million in compensatory damages and $25 million in punitive damages.

(I will note that there was a lot of discussion that this showed the jury was uncommonly disgusted with Gawker.)

Answer 4

Typically, a Prayer for Relief (the part of the lawsuit documents that includes the listed Relief) will request "Any other damages as the court sees fit" which allows for this. To my knowledge, it's not usually given beyond the damages sought, but does give the judge the ability to add on damages not directly sought.