Gorsuch v. Provident Security Life Insurance

“[w]e specifically approve of the district court’s use of special interrogatories, which can avoid the ‘inscrutable mystery of a general verdict [and] impenetrable uncertainty’”... | gross negligence: “Where a claim of breach of fiduciary duty is predicated upon underlying conduct, such as negligence, which is actionable in a direct suit at common law, the issue of whether there has been such a breach is ... a jury question.”