Breaux v. State Farm Insurance Co.

I respectfully submit that the award of the $100,000 policy limits is inadequate.

The award assumes that Breaux will not require further surgery and that he has a *23640% disability of the body as a whole. The record established to me that plaintiff will probably require additional surgery after which he could have an 80 to 90% disability of the body as a whole. Tr. 1050-1051.

Dr. Jackson testified that if the fusion did not heal and Breaux continues to have complaints, another operation may be indicated. Tr. 992. He testified that when three spaces are fused such as was done in this case, the…