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Tindley v. Salt Lake City School District5/17/2005
whether the legislature overstepped the bounds of its constitutional authority . . . , not whether it made wise policy in doing so.").
Having identified the cap's legitimate objective, we now address whether the aggregate cap satisfies the additional requirements of Utah's equal protection and due process guarantees. Under our equal protection analysis, a statute is constitutional if its classification is "a reasonable one and bears a reasonable relationship to the achievement of a legitimate legislative purpose." Mountain Fuel Supply Co. v. Salt Lake City Corp., 752 P.2d 884, 890 (Utah 1988). We conclude that the classifications inherent in the aggregate cap are both reasonable and reasonably related to accomplishing the Act's objective of protecting the fiscal resources of governmental entities. Damages arising from multiple-victim accidents resulting in personal injury are extremely difficult to predict and have a much greater potential than any single-victim accident for giving rise to a judgment that could drastically deplete the resources of a governmental entity. A judgment in favor of numerous plaintiffs against a small municipality for damages resulting from a catastrophic event could have a devastating impact on the municipality's fiscal health. The aggregate cap protects against such a result by limiting the damages the municipality can be required to pay to multiple victims. Although we acknowledge that the legislature could have selected a less severe means to achieve this objective, the level of scrutiny we employ in this case does not require the statute to embody the best solution. See Condemarin, 775 P.2d at 386 (Hall, C.J., dissenting). Consequently, we hold that the aggregate cap satisfies the demands of equal protection.
We reach a similar conclusion with respect to plaintiffs' claims under the due process clause. As stated above, a statute does not offend due process if it has a "reasonable relation to a proper legislative purpose, and neither arbitrary nor discriminatory." Id. at 352 (internal quotations omitted). As recognized in our equal protection analysis, the aggregate cap is reasonably related to a legitimate governmental objective. Accordingly, we hold that the aggregate cap also satisfies the demands of due process.
Plaintiffs further assert that the cap violates the guarantee of equal protection found in the Fourteenth Amendment to the United States Constitution. In discussing the relationship between Utah's uniform operation of laws provision and the federal equal protection provision, "we have made clear that Utah's uniform operation of the laws provision is 'at least as exacting, and in some circumstances, more rigorous than the standard applied under the federal constitution.'" Whitmer v. City of Lindon, 943 P.2d 226, 230 (Utah 1997) (quoting Mountain Fuel, 752 P.2d at 889); see also Carrier v. Pro-Tech Restoration, 944 P.2d 346, 356 (Utah 1997) (declaring that, under a rational basis review, "the protection afforded by article I, section 24 is at least as rigorous as that provided by the United States Constitution"). Because the Act does not violate plaintiffs' rights under article I, section 24 of the Utah Constitution, it also "will pass federal muster." Whitmer, 943 P.2d at 230 (internal quotations omitted).
III. THE RIGHT TO RECOVER DAMAGES FOR WRONGFUL DEATH, ARTICLE XVI, SECTION 5 OF THE UTAH CONSTITUTION
The final issue we address is whether the Act violates the right to recover damages for injuries resulting in death, as guaranteed by article XVI, section 5 of the Utah Constitution. That provision provides that " he right of action to recover damages for injuries resulting in death shall never be abrog
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