Sanders v. Ahmed
364 S.W.3d 195
| Mo. | 2012Background
- Ronald Sanders obtained judgments for his wife's wrongful death; jury awarded $10,120,745.88 in total damages.
- The trial court reduced noneconomic damages to $1,265,207.64 under section 538.210 cap per defendant.
- Defendants sought cap application, periodic payments under section 538.220, and reduction under section 537.060; Sanders admitted settlements totaling $625,000.
- Sanders challenged the constitutionality of sections 538.210 and 538.220; court held them constitutional.
- Court remanded to address reduction under section 537.060 after reversing that portion.
- Draper, J. dissented; majority affirmed with remand on the reduction issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of the non-economic damages cap | Sanders argues cap violates art. I, sec. 22(a). | Ahmed Defendants contend legislature may limit statutory remedies and cap damages. | Constitutional; cap permitted. |
| Separation of powers and remittitur-like effect of the cap | Cap infringes judiciary’s remedial power and jury’s verdict | Cap is a legislative limitation on a statutory remedy, not a judicial act. | Constitutional; no separation of powers violation. |
| Period payments under 538.220 for wrongful death | 538.220 is unconstitutional on multiple grounds | 538.220 simply limits a remedy; permissible | Constitutional; trial court did not abuse discretion denying payments. |
| Reduction under 537.060 for settlements | Defendants must plead/prove joint liability and settlement terms | Presumptions of joint liability arise from pleadings and settlements; burden on defendant to prove applicability and amount | Reversed and remanded for determination of reduction under 537.060. |
Key Cases Cited
- Adams v. Children's Mercy Hosp., 832 S.W.2d 898 (Mo. banc 1992) (legislature may abrogate or limit remedies in statutory actions)
- Estate of Overbey v. Chad Franklin Nat'l Auto Sales N., LLC, 361 S.W.3d 364 (Mo. bANC 2012) (legislature authority to define remedies under statutorily created actions)
- Sundermeyer v. SSM Reg'l Health Servs., 271 S.W.3d 552 (Mo. banc 2008) (causation standards in medical malpractice actions)
- Callahan v. Cardinal Glennon Hosp., 863 S.W.2d 852 (Mo. banc 1993) (causation includes 'but-for' and proximate concepts)
- Glick v. Ballentine Produce, Inc., 396 S.W.2d 609 (Mo.1965) (wrongful death is statutory, not common-law)
- Diehl v. O'Malley, 95 S.W.3d 82 (Mo. banc 2003) (wrongful death claim is statutory; jury right preserved)
- Fust v. Attorney General, 947 S.W.2d 424 (Mo. banc 1997) (limits on punitive damages do not violate separation of powers)