A federal appellate court affirmed Mississippi's $1 million cap on noneconomic damages in a ruling Wednesday.

The litigation in the case ruled on by the 5th U.S. Circuit Court of Appeals in New Orleans in Lisa Learmonth v. Sears, Roebuck & Co. has a complex history.

Ms. Learmonth was seriously injured in a collision between her vehicle and a van operated by an employee of Hoffman Estates, Ill.-based Sears. After a trial in U.S. District Court in Aberdeen, Miss., she was awarded $4 million in compensatory damages. But the jury did not itemize the damages involved.

Based on a motion from Sears, the District Court held the award broke down to $90,098.40 for past medical expenses; $483,510 for future medical expenses; $1,207,486 for lost wage-earning capacity; and $2,218,905.60, or the remainder, for noneconomic damages. The District Court then reduced the $2.2 million in noneconomic damages to $1 million, pursuant to Mississippi's statutory cap on noneconomic damages.

Ms. Learmonth appealed that ruling, challenging the validity of Mississippi's noneconomic damages cap. She argued the cap violated the Mississippi Constitution's jury trial guarantee and separation of powers provisions.

The appellate court referred the constitutional question to the Mississippi Supreme Court, which in 2012 declined to consider the matter, stating that because it was not clear how the jury would have divided the award, it could not determine whether Ms. Learmonth had been awarded more than $1 million.

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The appellate then reconsidered the issue in its opinion Wednesday. “Our longstanding procedural rules prevent us from considering Learmonth's argument that the district court was prohibited from applying (the statutory) cap because the jury had not itemized its verdict,” it said.

The court also said the Mississippi Legislature “has not invaded the jury's fact-finding role in enacting (the cap).”

“Learmonth has failed to establish that the jury's award represents the remedy to which she is entitled at law,” said the ruling, also. “The controlling authority she offers provides only that Mississippi's jury guarantee permits a litigant to have a jury alone find the proper compensatory damages amount.”

Ms. Learmonth “failed to establish beyond a reasonable doubt that (the cap) violates Mississippi's constitutional separation of powers,” said the three-judge panel, in reaffirming the District Court's ruling.

Mississippi Gov. Phil Bryant said in a statement in response to the ruling: “Today is a good day for businesses across Mississippi because the Fifth Circuit has upheld an important protection against unpredictable and excessive damage awards. The Fifth Circuit Court's ruling reinforces the rule of law and bolsters our continued push to make Mississippi the most job-friendly state in the nation.”