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The Supreme Court of Oklahoma ruled Tuesday that legislative caps on noneconomic damages for bodily injury are unconstitutional.
In Beason v. I.E. Miller Services Inc., the state’s high court in a 5-4 decision reversed a trial court ruling, finding that the Legislature’s statutory limit of $350,000 on a plaintiff’s recovery unless special findings is prohibited by the Oklahoma Constitution.
Todd Beason was seriously injured when a boom from a crane fell and hit him. He underwent two amputations on parts of his arm, and brought a lawsuit against the employer of the man operating the crane. The case went to trial, and a jury awarded Mr. Beason $14 million and his wife $1 million. The jurors also signed a supplemental verdict form allocating $5 million of the total award to Mr. Beason as noneconomic damages.
The Oklahoma Legislation passed a law that took effect in 2011 stating that in any civil action arising from bodily injury, the amount of compensation that can be awarded for noneconomic losses cannot exceed $350,000; no cap was placed on awards for economic loss.
As a result, the district court reduced the total award to $9.7 million — $6 million in noneconomic damages and $350,000 to each of the Beasons in accordance with the cap. The Beasons filed a motion to conform the judgment to the jury’s verdict and argued that the law was unconstitutional.
The Oklahoma Supreme Court held that the statutory cap on noneconomic damages “is the type of special law that is forbidden by … the Oklahoma Constitution … because it targets for different treatment less than the entire class of similarly situated persons who sue to recover for bodily injury.”
The court held that because the statutory cap can be lifted if the injured party can show certain degrees of culpability, finding that it has no bearing on the extent of the suffering a victim sustains.
“Unlike the Legislature (which has imposed a discriminatory cap that favors only one party), the people of Oklahoma have shown a clear preference that damages for personal injury be based on an assessment of evidence by a jury in a proceeding where the interested parties have the equal right to be heard on that issue,” said the high court. “If the people of Oklahoma ever believe the jury system and judicial review are no longer effective to balance the competing interests over compensation in private personal-injury cases, then constitutional amendment — not a special law — is the proper way to provide such change.”
As a result, the court reversed the trial court’s judgment modifying the jury’s award of noneconomic damages and remanded with directions to enter judgment in the full amount of the jury’s verdict.
In his dissent, Associate Justice James Winchester, said that while the majority found that there should be no cap for pain and suffering and that “the Legislature has created an impermissible, special law,” he said the ruling is contrary to other legislative acts which incorporate caps, such as the Workers Compensation Act and the Governmental Tort Claims Act.
Associate Justice James Edmondson, who wrote a separate dissent, said the legislative cap “is included within the historically recognized role of a legislature in defining, creating, or abolishing a legal cause of action,” he said.
Attorneys in the case did not immediately respond to requests for comment.
Voters in Oklahoma on Tuesday approved a measure that will legalize the use, sale and growth of medical marijuana.