The Utah Court of Appeals today affirmed the decision of a trial court that choosing “Tier 2” limits a party to under $300,000 in damages, even if the jury awards more than twice that amount. In other words, you can’t go back after an unexpectedly-good verdict and “amend up” to Tier 3. The case is Pilot v. Hill, 2018 UT App 105. See my blog for July 2, 2016 for a fuller discussion of this case.