Smith v. United States

Summary

The Utah Supreme Court answered certified questions from the United States District Court for the District of Utah concerning whether Utah’s medical-malpractice noneconomic-damages cap applies to wrongful-death claims. The court held that article XVI, section 5 of the Utah Constitution protects certain economic and noneconomic wrongful-death damages from statutory limitation, and that the constitutional compensation exception applies only to schemes akin to workers’ compensation. It therefore held Utah Code section 78B-3-410 unconstitutional as applied to wrongful-death cases.

Holdings

1. Article XVI, section 5 of the Utah Constitution protects economic damages and certain noneconomic damages available in wrongful-death cases at the time of Utah's statehood, including losses relating to the deceased's financial productivity, assistance, association, care, comfort, companionship, nurture, pleasure, protection, society, and support. Damages for survivors' mental anguish and suffering are not constitutionally protected because they were unavailable at statehood.
2. The compensation exception in article XVI, section 5 applies only to compensation schemes akin to workers' compensation and does not authorize a statutory cap on tort damages based on medical-provider fault.
3. The noneconomic-damages cap in Utah Code section 78B-3-410 is unconstitutional as applied to wrongful-death cases to the extent it limits damages protected by article XVI, section 5 of the Utah Constitution.

Questions Presented

1. Whether Utah Code section 78B-3-410's limitation on noneconomic damages applies to wrongful-death claims caused by medical malpractice.
2. Whether the noneconomic-damages cap in Utah Code section 78B-3-410 is permissible under article XVI, section 5 of the Utah Constitution when applied to wrongful-death cases.
3. What categories of wrongful-death damages are protected by article XVI, section 5 of the Utah Constitution.
4. Whether the compensation exception in article XVI, section 5 applies to the medical-malpractice damages cap.

Disposition

other