Pilot v. Hill, 2019 UT 10 (Mar. 1, 2019)

Plaintiff’s complaint identified this personal injury suit as a Tier 2 case, but when the jury awarded damages in excess of $600,000, he sought to amend his tier designation post-trial under Rule 15(b)(1), which allows post-trial amendments to pleadings to conform to tried unpleaded issues.  Because a tier designation is a pleaded issue, the Supreme Court held that amendment of the Tier 2 designation post-trial was impermissible, and the trial court’s reduction of the judgment to $299,999.99 was proper.