California, United States of America
The following excerpt is from Moore v. Teed, 261 Cal.Rptr.3d 642, 48 Cal.App.5th 280 (Cal. App. 2020):
"To preserve for appeal a challenge to separate components of a plaintiffs damage award, a defendant must request a special verdict form that segregates the elements of damages. [Citations.] The reason for this rule is simple. Without a special verdict separating the various damage components, we have no way of determining what portionif any of an award was attributable to a particular category of damages challenged on appeal." ( Greer v. Buzgheia (2006) 141 Cal.App.4th 1150, 1158, 46 Cal.Rptr.3d 780.)
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