Last month, the Texas Supreme Court reduced a jury’s determination of punitive damages, after previously eliminating the jury’s award of damages for loss of inheritance. The case is named In re Columbia Medical Center of Las Colinas d/b/a Las Colinas Medical Center, ___ S.W.3d ___ (Tex. 2009)(3/12/10). It was a medical malpractice suit in which the Supreme Court upheld the jury’s finding that the hospital’s gross negligence caused the patient’s death. However, the Court disagreed with the jury that the evidence showed damages for loss of inheritance. Having lowered the judgment for the total actual damages, the Court then lowered the punitive damages awarded by the jury to punish the hospital for its gross negligence.
Punitive damages had been capped by the lower courts at “(1) two times any amount of economic damages plus (2) an amount equal to any noneconomic damages not exceeding $750,000.” But “[p]unitive damages awards that are statutorily capped are required to be recalculated when the actual damages against which they are measured are reduced on appeal.” This is required by “the statute capping punitive damages as measured against economic damages requires a reduction in punitive damages as a matter of law.” “[T]rial courts must give effect to statutory caps on damages when the parties raise the issue.”
Thus, by eliminating part of the actual damages, the Supreme Court lowered the overall total of actual damages, which caused it to then lower the punitive damages.