Cap on Punitive Damages Ruled Unconstitutional in the State of Missouri
In a unanimous decision on September 9, 2014, the Missouri Supreme Court held that a cap on punitive damages instituted by the Missouri legislature was unconstitutional. Lillian Lewellen v. Chad Franklin and Chad Franklin National Auto Sales North involved a jury verdict against a Kansas City car dealership for fraudulent misrepresentation. The plaintiff was awarded $25,000 in actual damages and $1,000,000 in additional punitive damages. Pursuant to a 2005 state statute limiting punitive damages to five times the amount of actual damages or $500,000, the trial court reduced the punitive amount to $500,000.
The Court ruled that because article I, section 22(a) of the Missouri Constitution guarantees that the right to a jury trial “shall remain inviolate,” a mandatory cap on punitive damages denies an individual his or her constitutional right to a trial by jury. Because the amount of damages were determined by the jury at the time the Missouri Constitution was adopted, a statutory cap imposed on those damages “necessarily changes and impairs the right of a trial by jury as heretofore enjoyed.”
This decision was a huge victory for the people of Missouri. Punitive damages exist to punish wrongdoers when actual damages may not be enough to deter them from future injurious acts. Giant corporations should not be allowed to use their vast resources to subvert the legal system and influence legislation that will protect them from liability for their actions going forward. The Missouri Supreme Court has ensured that punitive damages determinations will be made by the ordinary citizens who actually hear the facts of the individual case, rather than by a legislature that is too often beholden to lobbyists and corporate interests.