The Supreme Court of Missouri issued an opinion rejecting medical malpractice caps, which are limitations on the amount of money that can be awarded in a medical malpractice lawsuit. Deborah Watts filed a medical malpractice suit alleging that her son, Naython Watts, was born with disabling brain injuries because Cox Medical Centers and its associated physicians provided negligent health care services. The jury returned a verdict in favor of Watts and awarded her on behalf of her son $1.45 million in non-economic damages and $3.371 million in future medical damages. The trial court then reduced the non-economic damages to $350,000 as required by law.
The mother and son appealed and won in a 4-3 decision. The Supreme Court of Missouri heard the issue and agreed with Watts that the cap on non-economic damages violates the right to trial by jury along with several other rights granted in the Missouri Constitution. The right to trial by jury is a fundament right in the Missouri Constitution, providing, “the right of trial by jury as heretofore enjoyed shall remain inviolate…” The Court interpreted “heretofore enjoyed” to mean “[c]itizens of Missouri are entitled to a jury trial in all actions to which they would have been entitled to a jury when the Missouri Constitution was adopted” in 1820. Then, the Court split its analysis into two parts: (1) whether a medical negligence lawsuit for non-economic damages was within that right, and (2) whether or not capping money damages awarded by juries was consistent enough with the 1820 standard to “remain inviolate.”
The Court first determined that the old common law in place in 1820 did not cap jury awards but instead let the jury decide the liability and damages. Secondly, the Court found that requiring courts to cap what a jury awarded to a party violated that right. The Supreme Court of Missouri decided that capping medical malpractice awards granted by juries was changing the trial by jury right that was formerly granted. The caps were found unconstitutional.