State of Indiana v. John Doe, 987 N.E.2d 1066

Indiana caps punitive damages at the greater of three times compensatory damages or $50,000 and allocates 75% of such damages to the Violent Crime Victims Compensation Fund (VCF); juries are not informed of the cap or allocation.
Doe was awarded $150,000 in punitive damages in a childhood sexual abuse case; Stewart sought reduction under the cap.
Trial court denied reduction, ruling the cap/allocation violated Article 3, Section 1 (separation of powers) and Article 1, Section 20 (jury trial).
State intervened to protect the punitive damages award; the trial court later entered no-hearing order upholding Doe’s constitutional challenges.
The State appeals under mandatory, exclusive jurisdiction to review statutes challenged on constitutional grounds; the court reviews facial constitutionality de novo.
Indiana Supreme Court reverses, holding the cap and allocation provisions constitutional and remanding to reduce punitive damages and allocate funds to the VCF.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the cap on punitive damages violate Art. I, §20?	Doe contends the cap infringes jury-trial rights in civil actions.	State argues cap is a public policy cap within legislature's power and does not violate jury trial.	No violation; cap constitutional.
Does the allocation to the VCF violate Art. I, §20?	Doe asserts allocation defeats jury-right protections by diverting private punitive damages to a state fund.	State asserts allocation is permissible as a policy choice consistent with punitive purpose.	No violation; allocation constitutional.
Does the cap and allocation violate separation of powers (Art. III, §1)?	Doe claims judiciary power to remit excessive verdicts is usurped by legislative cap.	State contends legislature may delineate boundaries of judicial power; cap is a public policy judgment within legislative prerogative.	No violation; cap/allocation within legislative powers.
Is the cap/remittitur or allocation a remittitur?	Doe contends the cap/allocation function as a legislative remittitur reducing damages post-verdict.	State argues not remittitur; it sets statutory boundaries within which the court can exercise discretion.	Not remittitur; boundaries allowed by statute.

Johnson v. St. Vincent Hosp., Inc., 273 Ind. 374, 404 N.E.2d 585 (1980) (upheld compensatory damage cap as consistent with jury trial rights)
Cheatham v. Pohle, 789 N.E.2d 467 (Ind. 2003) (allocation of punitive damages to a victim fund within state authority)
Stroud v. Lints, 790 N.E.2d 440 (Ind. 2003) (jury trial not implicated by punitive damages determinations)
Anthony v. Gilbert, 4 Blackf. 348 (Ind. 1837) (historical view on exemplary damages and discretion of jury)
Exxon Shipping Co. v. Baker, 554 U.S. 471 (2008) (explains punitive damages philosophy and deterrence)
State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003) (due process considerations in punitive damages ratios)