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The Wyoming Supreme Court has upheld a zero damage award to the family of a woman killed in a hit-and-run accident 22 years ago, ruling that her children were not entitled to recover for mental anguish. On Nov. 2, 1980, 21-year-old Lynn Rae Knowles was walking along Interstate 25 in Casper, Wyo., when she was struck and killed by a pickup truck driven by Debora Eileen Corkill, also 21. Police found no identification on Knowles’ body, except for a note indicating that her name was Lynn. Known only as Lynn Doe, her information was entered into an unidentified-persons database, and her body was buried in an unmarked grave. Corkill fled the scene but was traced during the original investigation through pieces of her vehicle’s grill scattered on the highway. For 14 years, Knowles remained a mystery to her family. Married and divorced, she had left her two children in the custody of her ex-husband. Her father hired a private investigator, to no avail. After discrepancies in her file prompted further investigation, police exhumed her body in 1994 and were able to identify Knowles from dental records. An appellate court allowed Knowles’ father to proceed with a wrongful-death suit against Corkill, ruling that the statute of limitations did not apply because Knowles’ body had only recently been identified. But a 7th district jury last year, finding that Corkill was 52 percent responsible for the accident and Knowles was 48 percent responsible, declined to award any damages to Knowles’ family. Plaintiffs’ attorney Cameron S. Walker of Casper, Wyo.’s Schwartz Bon Walker & Studer speculated on the jury’s decision: “Lynn was a troubled young woman, so the jury apparently said we don’t know what kind of an influence she would have been to” her children. Wyoming law does not allow recovery for emotional damages or the grief of survivors, Walker said. It allows compensation only for the monetary rewards, or the benefits of care and companionship that a plaintiff was denied by the death. The plaintiffs appealed the jury’s verdict, but the Wyoming Supreme Court upheld it earlier this month. The court said the trial judge correctly precluded a psychologist’s testimony relating to the children’s feelings of abandonment after their mother disappeared, on grounds that it constituted mental anguish. Corkill was represented by Vlastos, Henley & Drell in Casper. The firm did not return calls. Knowles v. Corkill, No. 96-281 (Wyo. Sup. Ct.).

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