Janice Evans went to Rockdale Medical Center with a thunderclap headache, vomiting, and dangerously high blood pressure, but the emergency department did not diagnose a ruptured brain aneurysm. She later suffered multiple strokes and became permanently disabled. A jury found Rockdale 51 percent at fault and awarded past medical expenses and loss-of-consortium damages, but awarded nothing for past pain and suffering, future medical expenses, lost wages, or future pain and suffering. The trial court denied the plaintiffs’ motion for additur or a new trial on damages. The Georgia Court of Appeals held that the zero award for past pain and suffering was so inadequate as to shock the conscience under Georgia law. Because comparative negligence linked liability and damages, the retrial could not be limited to damages; it had to include all issues in the medical-malpractice claim, and the derivative loss-of-consortium claim had to be retried as well. The court reversed and remanded with direction. One judge concurred in the judgment only, and the opinion was physical precedent only.