Truelove v. Blount, 954 So.2d 1284, 1287 (Fla. 2d DCA 2007)(quoting McCarthy Bros. Co. v. Tilbury Constr., Inc., 849 So.2d 7, 9 (Fla. 1st DCA 2003). Festival Fun Parks. LLC v. Bellamy, 123 So.3d 684 (Fla. 4thDCA 2013)(affirmed in part, reversed in part, remanded with instructions; finding that jury ignored evidence presented at trial when reaching its verdict and relied on inaccurate modifications to economist's summary). As the First District Court of Appeal explains:
Dr. Masson testified that cervical surgery would cost $90,000 to $120,000, and that lumbar surgery would cost $60,000 to $90,000. While courts cannot allow juries to award amounts of damages beyond what is reasonably supported by the evidence presented, see, e.g., Festival Fun Parks, LLC v. Bellamy, 123 So.3d 684, 685–86 (Fla. 4th DCA 2013), the evidence presented in this case regarding the reasonably certain need for and costs of Thomas's palliative care alone was sufficient to support the jury's award of future medical expenses. See Metrolimo, Inc. v. Lamm, 666 So.2d 552 (Fla. 3d DCA 1995) (upholding future medical expenses award because the amount awarded was "within the range testified to by the plaintiff's witnesses").
In that regard, "[a] court cannot allow a jury to award a greater amount of damages than what is reasonably supported by the evidence at trial." Festival Fun Parks, LLC v. Bellamy , 123 So.3d 684, 685–86 (Fla. 4th DCA 2013) (quoting Truelove v. Blount , 954 So.2d 1284, 1287 (Fla. 2d DCA 2007) )."[O]nly medical expenses that are reasonably certain to be incurred in the future are recoverable."