Jodi McClay v. Airport Management Services, LLC

Summary

Justice Sharon G. Lee dissents from the Tennessee Supreme Court’s decision upholding Tennessee’s statutory cap on noneconomic damages. The dissent argues that Tennessee Code Annotated section 29-39-102 violates the constitutional right to trial by jury by overriding a jury’s determination of noneconomic damages in negligence actions.

Holdings

1. In the dissent's view, Tennessee Code Annotated section 29-39-102 is unconstitutional because it permits the legislature to override a jury's determination of noneconomic damages in a common-law negligence action.
2. In the dissent's view, the General Assembly may not diminish the constitutional jury-trial right by statute; any amendment to the Tennessee Constitution must proceed through the constitutional amendment and voter-ratification process.

Questions Presented

1. Whether Tennessee Code Annotated section 29-39-102 violates Article I, section 6 of the Tennessee Constitution by limiting a jury's award of noneconomic damages.
2. Whether the General Assembly may legislatively limit the amount of damages determined by a jury in a common-law negligence action without a constitutional amendment ratified by the voters.
3. Whether applying the statutory cap after a jury determines damages impermissibly invades the jury's constitutional role.

Disposition

other