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Kirkland v. Blaine County Medical Center6/29/2000
ill, 103 Idaho 19, 26, 644 P.2d 341, 348 (1982); see also Jones v. State Board of Medicine, 97 Idaho 859, 555 P.2d 399 (1976). The standard for determining "whether a classification is local or special is whether the classification is arbitrary, capricious or unreasonable." Sun Valley Co. v. City of Sun Valley, 109 Idaho 424, 429, 708 P.2d 147, 152 (1985) (citing Washington County v. Paradis, 38 Idaho 364, 369, 222 P.2d 775 (1923).
The Kirklands argue the classification created by I.C. § 6-1603 is arbitrary, capricious, or unreasonable because it arbitrarily discriminates between slightly and severely injured plaintiffs, and between tortfeasors who cause severe and moderate or minor injuries. The $400,000 cap on non-economic damages (adjusted for inflation) necessarily applies only to those cases where the plaintiff is severely injured, thereby allowing full recovery for those plaintiffs who suffer moderate injuries, but denying a full recovery to those who have suffered more severe injuries. Similarly, the Kirklands argue the statute arbitrarily decides those tortfeasors who have inflicted the most damage are entitled to have their liability for non-economic damages capped, while those who have inflicted minor or moderate injuries are liable for the full amount.
WRMC argues any classification created by I.C. § 6-1603 is reasonable and not arbitrary or capricious because the statute is a reasonable attempt by the legislature to address and solve important societal and economic concerns that large non-economic damage awards could drive up the cost of liability insurance to Idaho citizens. That, in turn, would create a situation where defendants would be unable to respond to judgments for either economic or non-economic damages, thus leaving Idaho citizens injured by negligent acts of others with little or no recourse for their injuries.
The legislative history behind I.C. § 6-1603 reveals the statute was passed as part of a larger legislative package aimed at addressing concerns that large civil jury verdicts were driving up the cost of liability insurance. As part of the bill which included I.C. § 6-1603, the legislature also included reforms to the liability insurance business so Idaho policyholders would have more control over the prices and conditions of liability insurance; legislation designed to encourage settlements by giving defendants additional incentive to settle and by giving the courts greater latitude to impose sanctions on those bringing frivolous lawsuits; and some limitations on the application of joint and several liability. See Act of April 1, 1987, ch. 278, 1987 Idaho Session Laws 571. By striking this balance between a tort victim's right to recover non-economic damages and society's interest in preserving the availability of affordable liability insurance, the legislature "is engaging in its fundamental and legitimate role of 'structur and accomodat the burdens and benefits of economic life.'" Patton v. TIC United Corp., 77 F.3d 1235, 1247 (10 th Cir. 1996) (citations omitted). Additionally, it should be noted I.C. § 6-1603 expressly exempts tortfeasors who are found to have acted recklessly or feloniously from the limitation of liability. Therefore, contrary to the Kirklands' assertions, the statute does not arbitrarily limit the liability of all defendants causing severe injuries. Because we find the state had a legitimate interest in protecting the availability of liability insurance for Idaho citizens, and I.C. § 6-1603 is neither an arbitrary, capricious, nor unreasonable method for addressing this legitimate societal concern, we find I.C. § 6-1603 does not violate the constitutional prohibition against special legislation.
C. Idaho Code § 6-1
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