Larimore Public School District No. 44 v. Aamodt, 908 N.W.2d 442

Larimore Public School District bus collided with a BNSF train in Jan. 2015; 13 students aboard, one killed and multiple children seriously injured.
Total damages from the accident stipulated to exceed $3 million; School District and its insurer deposited $500,000 under N.D.C.C. § 32-12.1-03(2) (statutory cap) and sought interpleader relief.
Parents of nine injured children challenged the statutory damage cap as unconstitutional under N.D. Const. art. I, § 9 (open courts), art. I, § 13 (jury trial), art. I, § 21 (equal protection), and art. IV, § 13 (special laws).
District court upheld the cap and discharged the School District and insurer from further liability; parents appealed.
The Supreme Court of North Dakota affirmed, holding the cap did not violate the cited constitutional provisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Open-courts / remedy (Art. I, § 9)	Cap denies meaningful redress and access to courts; abridges guaranteed remedy	Right of access not absolute; cap does not totally bar recovery and serves public interest	Cap does not violate open-courts clause; not an absolute bar or so low as to be equivalent to none
Jury-trial (Art. I, § 13)	Cap invades jury province by limiting recovery that juries historically determined	Cap preserves jury factfinding; only limits recoverable amount from political subdivisions	Cap does not violate jury-trial clause; jury may decide facts though recovery from subdivision is capped
Equal protection (Art. I, § 21)	Cap irrationally treats victims differently by tortfeasor identity and limits recovery for catastrophic multi-victim events	Legislature reasonably distinguished political subdivisions due to fiscal realities and mandated public services	Intermediate scrutiny applies; statute bears close correspondence to legitimate legislative goals and is constitutional
Special/local laws (Art. IV, § 13)	Cap effectively creates special protections or disparate treatment	Cap is a general law applying equally to similarly situated political subdivisions and claimants	Statute is a general law and does not violate special-law provision

Kitto v. Minot Park Dist., 224 N.W.2d 795 (N.D. 1974) (judicially abrogated governmental immunity and recognized legislature may limit liability)
Nelson v. Gillette, 571 N.W.2d 332 (N.D. 1997) (political-subdivision liability generally equated to private liability in context)
Arneson v. Olson, 270 N.W.2d 125 (N.D. 1978) (statutory scheme requiring nonjury trials violated right to jury trial; intermediate scrutiny for damage limits in malpractice context)
Bouchard v. Johnson, 555 N.W.2d 81 (N.D. 1996) (open-courts analysis; statutory immunities construed to avoid absolute bar to remedy)
Herman v. Magnuson, 277 N.W.2d 445 (N.D. 1979) (upheld filing-condition statutes under governmental fiscal-planning rationale)
Zauflik v. Pennsbury Sch. Dist., 104 A.3d 1096 (Pa. 2014) (upheld similar municipal damages cap under intermediate scrutiny; legislative balancing of public fisc vs. claimant recovery)
Cauley v. City of Jacksonville, 403 So. 2d 379 (Fla. 1981) (statutory municipal damage caps do not inherently violate open-courts provisions)
Wells v. Panola Cty. Bd. of Educ., 645 So. 2d 883 (Miss. 1994) (upheld school-district liability cap against open-courts challenge)