Tennessee Supreme Court Rejects Constitutionality Ruling on Damages Cap

The Tennessee Supreme Court has vacated the decision of a trial court that ruled a state law putting a cap on certain personal injury damages is unconstitutional.

The decision stems from a negligence lawsuit brought by Donald and Beverly Clark against several divisions of AT&T and one of its employees, Aimee L. Cain. According to the Tennessee Supreme Court’s opinion, the couple sued the defendants for $25 million in non-economic damages as a result of a car accident that injured Donald Clark. In the suit, the couple also asked the trial court to declare the state law that caps non-economic damages at $750,000 for certain personal injury cases as unconstitutional.

The defendants in turn moved for partial summary judgement as a way to limit any award of non-economic damages to the amount permitted under the statute. The Hamilton County trial judge denied the defendants’ motion and held that the statute is unconstitutional.

The trial court then granted the defendants an interlocutory appeal, which seeks to appeal specific elements of a case while it is still being considered in a lower court. This move sent the case to the Tennessee Court of Appeals and paused the trial proceedings until the appeal was resolved.

The jury for the case had not made a decision as to liability or any amount of damages when the interlocutory appeal was granted. For that reason, the Court of Appeals declined to consider the issue saying the plaintiffs had not yet been, and might never be, awarded a judgement in excess of the cap.

The parties then requested the state Supreme Court resolve the issue of the constitutionality of the statutory cap on non-economic damages, which the court declined to do. The court determined that the trial court had acted prematurely in considering the motion for summary judgement on the issue of damages.

“The statutory cap on non-economic damages will have no relevance in this case unless and until plaintiffs obtain a verdict in excess of that cap,” the opinion says.

The justices said whether the cap is implicated is still an “open question” in the case and the issue “of the constitutionality of that cap is not ripe for determination at this time.”

“The trial court, therefore, acted prematurely in considering defendants’ motion for partial summary judgement and plaintiffs’ constitutional challenge at this state of the proceedings,” the opinion states.

The justices concluded that the trial court judgment is vacated and remanded the case to the trial court.