Constitutional Invalidity of Illinois Civil Justice Reform Act 1995

Constitutional Invalidity of Illinois Civil Justice Reform Act 1995

Introduction

The case of Vernon Best v. Taylor Machine Works et al. consolidated with Jonathan Isbell v. Union Pacific Railroad Company et al. presents a pivotal moment in Illinois tort law. The plaintiffs challenged the constitutionality of Public Act 89-7, known as the Civil Justice Reform Amendments of 1995, arguing that it violated multiple provisions of the Illinois Constitution of 1970. The Supreme Court of Illinois affirmed the Circuit Court's judgment, declaring significant portions of the Act unconstitutional. This commentary delves into the intricacies of the case, analyzing the legal reasoning, precedents cited, and the broader impact on Illinois tort law.

Summary of the Judgment

The Supreme Court of Illinois upheld the Circuit Court of Madison County's decision, which found several provisions of Public Act 89-7 unconstitutional. The invalidated provisions include:

  • The $500,000 cap on compensatory damages for noneconomic injuries (735 ILCS 5/2-1115.1)
  • The allocation of fault and several liability provisions (735 ILCS 5/2-1116, 735 ILCS 5/2-1117)
  • Amendments to the Joint Tortfeasor Contribution Act (740 ILCS 100/3.5, 5)
  • Certain jury instructions (735 ILCS 5/2-1107.1)
  • The product liability certificate of merit (735 ILCS 5/2-623)
  • The product liability statute of repose (735 ILCS 5/13-213(b))
  • The product liability presumptions (735 ILCS 5/2-2103, 735 ILCS 5/2-2104, 735 ILCS 5/2-2106)
  • The discovery statutes mandating mandatory disclosure of plaintiffs' medical information (735 ILCS 5/2-1003, 735 ILCS 5/8-802, 735 ILCS 5/8-2001, 735 ILCS 5/8-2003)

Consequently, the Act was invalidated in its entirety as the unconstitutional provisions could not be severed from the rest of the legislation.

Analysis

Precedents Cited

The judgment extensively references prior Illinois Supreme Court decisions that address similar constitutional challenges:

  • Wright v. Central Du Page Hospital Ass'n (63 Ill.2d 313, 1976): Invalidated a $500,000 cap on compensatory damages in medical malpractice actions.
  • GRACE v. HOWLETT (51 Ill.2d 478, 1972): Struck down a damages cap differentiating between commercial and private motorists.
  • GRASSE v. DEALER'S TRANSPORT CO. (412 Ill. 179, 1952): Invalidated discriminatory classifications in workers' compensation provisions.
  • ANDERSON v. WAGNER (79 Ill.2d 295, 1979): Upheld a statute imposing a discovery rule in medical malpractice, distinguishing it from the current case.

These cases collectively establish the judiciary's role in scrutinizing legislative classifications to ensure they do not constitute special legislation or violate equal protection.

Legal Reasoning

The court began with the principle that legislation is presumed constitutional, and the burden lies with plaintiffs to demonstrate unconstitutionality. The analysis focused on several constitutional provisions:

1. Special Legislation Clause

Provision: Article IV, Section 13 of the Illinois Constitution prohibits the General Assembly from passing special or local laws when a general law suffices.

Application: The court found that Public Act 89-7 created arbitrary classifications by imposing a blanket cap on noneconomic damages, thereby conferring a disproportionate benefit to tortfeasors exempted from full liability.

Based on precedents like Wright, Grace, and Grasse, the court determined that the Act's provisions were arbitrary and unfairly discriminated against similarly situated plaintiffs and defendants.

2. Separation of Powers

Provision: Article II, Section 1 of the Illinois Constitution enforces the separation of powers among the legislative, executive, and judicial branches.

Application: The statute's mandatory caps on damages were characterized as an infringement on the judiciary's inherent authority to manage trials and assess damages on a case-by-case basis. By imposing a statutory remittitur, the legislature overstepped into judicial territory.

3. Right to a Certain Remedy and Jury Trial

Provision: Articles I, Sections 12 and 13 of the Illinois Constitution guarantee the right to a certain remedy and a jury trial.

Application: The mandatory disclosure of medical records without regard to relevance undermined the plaintiff's right to a fair trial and a certain remedy, as it could lead to prejudicial information being admitted into evidence.

Impact

The invalidation of Public Act 89-7 has profound implications for Illinois tort law:

  • Damages Caps: Plaintiffs can no longer be subjected to arbitrary limits on noneconomic damages, ensuring that compensation for pain and suffering aligns with the injury's severity.
  • Joint and Several Liability: Reinstated doctrines ensure that liable parties cannot escape full responsibility, promoting fairness in tort claims.
  • Discovery Procedures: The mandatory disclosure provisions were nullified, preserving the judiciary's role in safeguarding the integrity of the trial process and protecting plaintiffs' privacy.
  • Legislative Oversight: The decision reinforces the judiciary's power to check legislative actions that overstep constitutional boundaries, maintaining the balance of power.

Future tort reforms in Illinois will need to carefully navigate constitutional provisions, ensuring that any legislative changes do not infringe upon the rights protected by the Illinois Constitution.

Complex Concepts Simplified

Special Legislation Clause

This constitutional provision prevents the legislature from creating laws that unduly favor specific groups or individuals over others in similar situations. It ensures that laws are general in nature and serve the public interest without arbitrary discrimination.

Separation of Powers

Designed to prevent any one branch of government from encroaching upon the functions of another, this doctrine maintains a balance by clearly delineating the powers of the legislative, executive, and judicial branches.

Joint and Several Liability vs. Proportionate Several Liability

Joint and Several Liability: Each defendant is individually responsible for the entire amount of damages, regardless of their individual share of fault.

Proportionate Several Liability: Each defendant is only responsible for their respective share of the damages based on their degree of fault.

The shift from joint and several liability to proportionate several liability restricts defendants from being liable beyond their actual contribution to the harm suffered.

Conclusion

The Supreme Court of Illinois' invalidation of Public Act 89-7 underscores the judiciary's essential role in upholding constitutional protections against arbitrary legislative actions. By striking down the damages cap, the abolition of joint and several liability, and the mandatory medical disclosures, the court has reinforced the rights of plaintiffs to fair compensation and the judiciary's authority to manage trials without legislative interference. This decision shapes the future landscape of tort law in Illinois, ensuring that reforms align with constitutional mandates and uphold the principles of fairness and justice.

Case Details

Year: 1997
Court: Supreme Court of Illinois. Circuit court judgment affirmed.

Judge(s)

JUSTICE BILANDIC, specially concurring: JUSTICE MILLER, concurring in part and dissenting in part:

Attorney(S)

John W. Hoffman and Michael Reda, of Evans Dixon, of Edwardsville, for appellant Taylor Machine Works. Karen L. Kendall, of Peoria, and Robert H. Schultz, Jr., and Robert D. Rowland, of Edwardsville, all of Heyl, Royster, Voelker Allen, for appellant Lee Helms, Inc. Timothy M. Palumbo, of Chicago, and Gary S. Wolfe and John J. Pawloski, of St. Louis, Missouri, all of Landau, Omahana Kopka, P.C., for appellant Allied Industrial Equipment Corp. Thomas E. Jones and Leslie G. Offergeld, of Walker Williams, P.C., of Belleville, and Richard K. Willard, Thomas M. Barba and Brian J. Leske, of Steptoe Johnson, LLP, of Washington, D.C., for appellants Union Pacific Railroad Co. and Donald F. Cain. Jon G. Carlson and Eric J. Carlson, of Carlson, Wendler Associates, P.C., of Edwardsville, Theodore R. Diaz and David W. Dugan, of Pitts, Dugan Diaz, of Wood River, Charles R. Abele, of St. Louis, Missouri, and Laurence H. Tribe, of Cambridge, Massachusetts, for appellee Vernon Best. Jon G. Carlson and Eric J. Carlson, of Carlson, Wendler Associates, P.C., of Edwardsville, and Laurence H. Tribe, of Cambridge, Massachusetts, for appellee Jonathan Isbell. Barbara A. Preiner, Solicitor General, of Chicago (Deborah L. Ahlstrand, A. Benjamin Goldgar and Laura M. Wunder, Assistant Attorneys General, of counsel), for intervenor James E. Ryan, Attorney General. Joan M. Mannix and Margaret Pardo, of Addison, for amicus curiae Breast Implant Information Exchange. Kathy Byrne, of Conney Conway, of Chicago, for amici curiae Brotherhood of Heat Frost Insulators, Local 17 et al. Ellen A. Yearwood, of Springfield, for amicus curiae Illinois NOW Legal Education Fund. Tracy L. Meares, of Chicago (Frederick H. Bates and Furmin D. Sessoms, of counsel), for amici curiae National Association for the Advancement of Colored People et al.

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