Watts ex rel. Watts v. Lester E. Cox Medical Centers
2012 WL 3101657, 2012 Mo. LEXIS 155, 376 S.W.3d 633 (2012)
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Rule of Law:
A statutory cap on non-economic damages for a common-law cause of action, such as medical malpractice, violates the state constitutional right to a trial by jury by impermissibly infringing on the jury's fact-finding function of determining damages.
Facts:
- Deborah Watts received prenatal care from physicians associated with Cox Medical Centers.
- On October 30, 2006, when Watts was 39 weeks pregnant, she visited a Cox clinic reporting cramping and decreased fetal movement.
- A medical resident, Dr. Herrman, examined Watts but allegedly failed to perform appropriate tests or diagnostic monitoring.
- On November 1, 2006, Watts was admitted to the hospital due to a lack of fetal movement.
- Diagnostic monitoring at 9:10 a.m. indicated fetal distress, for which the standard of care required an immediate Caesarean-section.
- The Caesarean-section was not started until 10:45 a.m.
- Watts' son, Naython Watts, was born with catastrophic and disabling brain injuries.
Procedural Posture:
- Deborah Watts filed a medical malpractice action against Cox Medical Centers in a Missouri trial court.
- A jury found in favor of Watts and awarded $1.45 million in non-economic damages and $3.371 million in future medical damages.
- The trial court, pursuant to Missouri statute § 538.210, entered a judgment reducing the non-economic damages award to the statutory cap of $350,000.
- The trial court also established a periodic payment schedule for future medical damages per § 538.220.
- Watts appealed directly to the Supreme Court of Missouri, challenging the constitutionality of the statutory damages cap.
- Cox filed a cross-appeal challenging the trial court's order for the periodic payment schedule.
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Issue:
Does a statutory cap on non-economic damages in medical malpractice cases, as codified in Missouri statute § 538.210, violate the Missouri Constitution's guarantee that the right to trial by jury as heretofore enjoyed shall remain inviolate?
Opinions:
Majority - Teitelman, C.J.
Yes, the statutory cap on non-economic damages violates the Missouri Constitution's right to trial by jury. Article I, section 22(a) of the Missouri Constitution guarantees the right to a jury trial 'as heretofore enjoyed shall remain inviolate,' which refers to the right as it existed at common law in 1820. Because medical malpractice was a cause of action recognized at common law, and determining the amount of damages was a fundamental part of the jury's fact-finding role, a legislative cap directly curtails this constitutionally protected function. The cap nullifies the jury's factual determination of damages, preventing the right from remaining 'inviolate.' This decision overrules the prior precedent of Adams v. Children's Mercy Hosp., which incorrectly held that the cap was a matter of law applied after the jury's task was complete; this Court finds that such a rationale impermissibly allows a statute to limit a constitutional right.
Dissenting-in-part-and-concurring-in-part - Russell, J.
No, the statutory cap on non-economic damages does not violate the Missouri Constitution's right to trial by jury. Under the doctrine of stare decisis, the Court should adhere to its well-reasoned and controlling precedent in Adams v. Children's Mercy Hosp., which held that the cap is constitutional. The jury's constitutional task is to find facts, including the amount of damages. The statutory cap is a matter of law applied by the judge after the jury has completed its fact-finding function. Therefore, the statute does not interfere with the jury's role. The majority's decision to overrule Adams is an improper policy judgment that should be left to the legislature, and it disregards that numerous other states with similar 'inviolate' constitutional language have upheld such caps.
Analysis:
This decision marks a significant shift in Missouri tort law by invalidating a key component of legislative tort reform aimed at curbing medical malpractice awards. By overruling the 20-year-old precedent of Adams, the Court re-asserted the primacy of the jury's role in determining damages for common-law claims. This ruling strengthens plaintiffs' positions in malpractice litigation and makes it substantially more difficult for the legislature to limit recoveries without a constitutional amendment. The decision signals a robust judicial protection of the jury trial right against legislative encroachment, potentially impacting future tort reform efforts beyond the medical malpractice context.
