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Keywords

lawsuitdamagestrialverdictmalpracticepunitive damagesjury trial

contracttortplaintiffdamagestrialpunitive damages

Related Cases

Smith v. Schulte, 671 So.2d 1334

Facts

Annie Jo Smith suffered severe injuries in an automobile accident and was admitted to Knollwood Park Hospital, where her condition worsened. Dr. Schulte, after assessing her respiratory issues, administered Pavulon, a drug that paralyzed her muscles, including those necessary for breathing. Due to a medical error, the endotracheal tube was incorrectly placed, leading to cardiac arrest and ultimately her death four days later. Woodrow Smith filed a lawsuit alleging medical malpractice against Dr. Schulte and PAM, resulting in a jury verdict of $4.5 million in punitive damages.

On September 28, 1989, Annie Jo Smith was involved in an automobile accident in which she suffered contusions to the upper body and multiple fractures, including fractures of the ribs and hip. She was admitted to Knollwood Park Hospital in Mobile, where she was surgically treated for the fractured hip and was placed in the intensive care unit.

Issue

The main legal issues were whether the statutory cap on damages in wrongful death actions violated the Alabama Constitution and whether the punitive damages awarded were excessive.

Smith challenges on two grounds the constitutionality of § 6–5–547, which provides in pertinent part: 'In any action commenced pursuant to Section 6–5–391 or Section 6–5–410, against a health care provider whether in contract or in tort based on a breach of the standard of care the amount of any judgment entered in favor of the plaintiff shall not exceed the sum of $1,000,000.'

Rule

The court applied principles regarding the right to trial by jury and equal protection under the Alabama Constitution, determining that the statutory cap on damages was unconstitutional.

We now hold that § 6–5–547 represents a similar form of 'class legislation' that is unreasonable, and, therefore, violates the equal protection guarantee of the Constitution of Alabama.

Analysis

The court found that the statutory cap imposed by Ala.Code 1975, § 6–5–547 limited recovery in wrongful death actions and violated the equal protection guarantee of the Alabama Constitution. The court emphasized that the cap created unreasonable classifications among citizens and infringed upon the fundamental right to a jury trial by restricting the jury's ability to determine damages based on the facts of the case.

The court found that the statutory cap imposed by Ala.Code 1975, § 6–5–547 limited recovery in wrongful death actions and violated the equal protection guarantee of the Alabama Constitution.

Conclusion

The Supreme Court of Alabama reversed the trial court's reduction of the punitive damages award, holding that the statutory cap was unconstitutional, and remitted the punitive damages to $2.5 million.

Who won?

Woodrow Smith prevailed in part, as the court ruled the statutory cap unconstitutional, allowing for a higher punitive damages award than the cap would have permitted.

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