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Keywords

lawsuitdamagesnegligencestatutetrialdue processjury trial
plaintiffdamagesstatutetrialdue processappelleejury trial

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Gladon v. Greater Cleveland Regional Transit Authority, Not Reported in N.E.2d, 1994 WL 78468

Facts

On April 27, 1988, Robert M. Gladon was struck by a train operated by Mary Bell after being attacked and left lying on the tracks. Gladon suffered severe injuries, leading to a lawsuit against RTA for negligence, seeking $2.5 million in damages. The jury awarded him $2,736,915.35, which was later reduced to comply with the collateral source rule and the demand amount. RTA challenged the jury's award and the constitutionality of the damage cap under R.C. 2744.05(C)(1).

On April 27, 1988, Robert M. Gladon, plaintiff-appellee, was struck by a rapid train operated by Mary Bell.

Issue

Is R.C. 2744.05(C)(1) unconstitutional for infringing upon the jury trial right as guaranteed by Section 5, Article I of the Ohio Constitution?

the primary one is whether R.C. 2744.05(C)(1) is unconstitutional.

Rule

The right to a jury trial is fundamental and requires strict scrutiny under both due process and equal protection clauses. Legislative enactments that infringe upon this right must demonstrate a compelling justification.

The right to a jury trial is fundamental and requires strict scrutiny under both the due process and equal protection clauses.

Analysis

The court found that R.C. 2744.05(C)(1) undermines the jury's authority to determine damages, as it imposes a cap on non-economic damages that could deter litigants from exercising their right to a jury trial. The court applied strict scrutiny and concluded that the statute failed to provide a compelling justification for its existence, rendering it unconstitutional.

It is invalid because it violates Section 5, Article I of the Ohio Constitution's mandate that the jury trial right shall be inviolate.

Conclusion

The court affirmed the trial court's ruling that R.C. 2744.05(C)(1) is unconstitutional, as it violates the fundamental right to a jury trial by capping non-economic damages.

the trial court held that R.C. 2744.05(C)(1) was unconstitutional and refused to cap the amount of non-economic damages.

Who won?

Robert M. Gladon prevailed in the case because the court upheld the jury's award and ruled that the damage cap statute was unconstitutional, thus allowing him to retain the full amount awarded by the jury.

RTA then asked the trial court to reduce the factual finding of $2.5 million to the legislative predetermined amount of $250,000. The trial court refused to reduce the jury's finding of non-economic damages from $2.5 million to $250,000 and held as a matter of law that R.C. 2744.05(C)(1), the $250,000 cap or reduction statute, was unconstitutional.

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