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Keywords

damageslitigationnegligencestatutetrialpunitive damagescommon law
damageslitigationstatuteappealpunitive damagesappellantappellee

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Williams v. Wilson, 972 S.W.2d 260

Facts

On May 18, 1990, Patricia Lynn Herald Wilson was struck by a vehicle driven by an intoxicated driver while on her way to work. The intoxicated driver was arrested and pled guilty to DUI. Wilson initiated litigation seeking compensatory and punitive damages, but the intoxicated driver did not participate in the trial. The trial court initially refused to instruct the jury on punitive damages based on the statutory standard, but later allowed it based on common law gross negligence after Wilson argued the statute was unconstitutional.

The facts which give rise to this litigation are unremarkable but not unimportant. On May 18, 1990, at 7:00 a.m., appellee, Patricia Lynn Herald Wilson, was en route to the place of her employment as a school teacher. As she approached the intersection of Man–O–War and Palumbo in Lexington, she was struck by the vehicle being driven by appellant, a person who was intoxicated.

Issue

Does KRS 411.184 violate the Constitution of Kentucky by altering the common law right to recover punitive damages?

This Court granted discretionary review (CR 76.20) to consider whether KRS 411.184 violates one or more provisions of the Constitution of Kentucky, thereby rendering the statute invalid and unenforceable.

Rule

The court applied the doctrine of jural rights, which protects common law rights from legislative alteration, particularly regarding the recovery of punitive damages for gross negligence.

In general, the intent of the Legislature was to redefine the circumstances in which punitive damages were recoverable, and toward that end a new legal standard was established.

Analysis

The court found that KRS 411.184 imposed a higher standard for punitive damages than the common law gross negligence standard, which had allowed recovery based on objective measures of negligence. The court determined that the statute's requirement for subjective awareness of harm effectively eliminated the common law right to punitive damages, thus violating the jural rights doctrine.

The court found that the evidence did not support a jury finding of 'malice' as defined in the statutes sufficient to warrant a jury instruction on the issue.

Conclusion

The Supreme Court affirmed the lower court's ruling that KRS 411.184 was unconstitutional, thereby upholding the common law right to recover punitive damages based on gross negligence.

Affirmed and remanded.

Who won?

Patricia Lynn Herald Wilson prevailed in the case because the court found that the statutory standard for punitive damages violated her constitutional rights under the jural rights doctrine.

The Fayette Circuit Court and the Court of Appeals decided the constitutional question and invalidated the statute on the view that it offends Sections 14, 54 and 241 of the Constitution of Kentucky.

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