Is a jury's award for damages in a medical malpractice case duplicative?

Duplication of recovery occurs "by compensating a single injury under two different names," Hysell v. Iowa Public Serv. Co., 559 F.2d 468, 473 (8th Cir.1977). However, defendants do not demonstrate that a jury's award is duplicative merely by noting that it allocated the damages under two different causes of action. It is, of course, possible that the jury committed the error of duplicating damages here, but defendants have failed to establish this allegation with any degree of certainty.