Invalidation of Medical Review Panels and Recovery Limitations in Medical Malpractice Cases

Invalidation of Medical Review Panels and Recovery Limitations in Medical Malpractice Cases

Introduction

The case of Jean Mary Wright et al. v. Central Du Page Hospital Association et al. adjudicated by the Supreme Court of Illinois on May 14, 1976, addresses significant constitutional challenges to legislative provisions affecting medical malpractice litigation. The appellant, Central Du Page Hospital Association along with Dr. John A. Heitzler and others, appealed the circuit court's declaratory judgment that found certain sections of the Civil Practice Act and the Illinois Insurance Code unconstitutional. The key issues revolve around the constitutionality of medical review panels and the imposition of a monetary cap on damages in medical malpractice lawsuits.

Summary of the Judgment

The Supreme Court of Illinois reviewed consolidated cases challenging the constitutionality of section 401a of the Illinois Insurance Code and sections 58.2 through 58.10 of the Civil Practice Act, added by Public Act 79-960. The circuit court had previously held these sections unconstitutional, a decision partially affirmed and partially vacated by the Supreme Court. The court found that the establishment of medical review panels, which included nonjudicial personnel like physicians and attorneys with equal authority to judges in determining liability and compensation, violated the Illinois Constitution by encroaching on judicial powers. Additionally, the court struck down the $500,000 cap on damages in medical malpractice cases as arbitrary and constituting special legislation, thereby denying plaintiffs equal protection and due process.

Analysis

Precedents Cited

The judgment extensively references prior cases to support its findings:

  • People v. Bruner (1931): Established that the application of legal principles is inherently a judicial function.
  • AGRAN v. CHECKER TAXI CO. (1952): Affirmed that judicial power is exclusively vested in the courts.
  • People v. Lobb (1959): Interpreted the right to trial by jury as encompassing the determination of facts by an impartial jury under judicial supervision.
  • HALL v. GILLINS (1958) and CUNNINGHAM v. BROWN (1961): Examined the legislature's authority to impose limitations on damages in specific contexts, distinguishing between common law and statutory causes of action.
  • MOUSHON v. NATIONAL GARAGES, INC. (1956): Supported legislative modifications to common law in the interest of public welfare.
  • LI PETRI v. TURNER CONSTRUCTION CO. (1967): Addressed the unconstitutionality of differential treatment under special legislation.
  • DAVIS v. COMMONWEALTH EDISON CO. (1975), GRACE v. HOWLETT (1972), and HARVEY v. CLYDE PARK DISTrict (1964): Reinforced the prohibition against arbitrary and special legislation.

These precedents collectively underscore the judiciary's role in safeguarding constitutional guarantees against legislative overreach, particularly concerning the separation of powers and equal protection under the law.

Impact

The judgment has profound implications for both the administration of justice and the regulation of medical malpractice litigation in Illinois:

  • Judicial Independence: Reinforces the separation of powers by affirming that judicial functions cannot be delegated to nonjudicial personnel, safeguarding the judiciary's role in fact-finding and ruling on substantive legal issues.
  • Trial by Jury: Upholds the constitutional guarantee of jury trials in civil cases, preventing legislative measures from imposing prerequisites that infringe upon this fundamental right.
  • Legislative Boundaries: Sets a precedent limiting the legislature's ability to enact laws that arbitrarily classify and target specific areas of law without a clear, rational justification tied to public welfare objectives.
  • Future Legislation: Legislators must ensure that any reforms to medical malpractice litigation, such as the establishment of review panels or damage caps, are constitutionally sound, with clear rationales and equitable applications that do not single out specific types of litigation without cause.

Future cases involving legislative attempts to modify judicial processes or impose constraints on legal remedies will reference this judgment to assess constitutionality, particularly concerning equal protection and the inviolable right to jury trials.

Complex Concepts Simplified

Medical Review Panels

These are panels established by legislation to review medical malpractice claims before they proceed to trial. In this case, the panels included judges, physicians, and attorneys who jointly determined liability and compensation, which the court found infringed upon the judiciary's exclusive authority.

Special Legislation

Laws that apply to specific individuals or groups rather than the general population without a rational basis. Such laws are prohibited as they violate principles of equal protection.

Quid Pro Quo

A situation where one thing is given in exchange for another. In legal terms, it often refers to a reciprocal arrangement necessary to justify certain legislative actions.

Equal Protection and Due Process

Constitutional guarantees that ensure individuals are treated fairly and that laws do not arbitrarily discriminate against any group or individual.

Monetary Cap on Damages

A legal limit set on the amount of money that can be awarded to plaintiffs in lawsuits. In this case, the cap was $500,000 for medical malpractice claims.

Conclusion

The Supreme Court of Illinois' decision in Jean Mary Wright et al. v. Central Du Page Hospital Association et al. serves as a crucial affirmation of judicial autonomy and the inviolable right to jury trials in civil cases. By invalidating the medical review panels and the cap on malpractice damages, the court underscored the necessity for legislative measures to align strictly with constitutional mandates. This judgment ensures that mechanisms intended to reform medical malpractice litigation do not erode fundamental legal protections or the integrity of the judicial process. As a result, it sets a definitive benchmark for evaluating the constitutionality of similar legislative endeavors in the future, reinforcing the checks and balances essential to the American legal system.

Case Details

Year: 1976
Court: Supreme Court of Illinois.

Judge(s)

MR. JUSTICE UNDERWOOD, concurring in part and dissenting in part:

Attorney(S)

Howard French, of Chicago (Richard G. French and Michael C. Kominiarek, of counsel), for appellant Central Du Page Hospital Association. Frederic O. Floberg, of Chicago (William D. Serritella, Michael J. Critelli, and Ross, Hardies, O'Keefe, Babcock Parsons, of counsel), for appellant Dr. John A. Heitzler. William J. Scott, Attorney General, of Chicago (Paul J. Bargiel and Patricia Rosen, Assistant Attorneys General, of counsel), for appellant Robert B. Wilcox, Director of Insurance. Nat P. Ozmon, Leonard M. Ring and William J. Harte, of Chicago (Laurence T. Stanner, Ralph L. Brill, Karla Wright and Timothy M. O'Brien, of counsel), for appellee Jean Mary Wright. Joseph Keig, Jr., and Bennet B. Harvey, Jr., both of Chicago (William G. Schopf, Jr., John A. McLees, and Keck, Cushman, Mahin Cate, of counsel), for appellee Hartford Casualty Insurance Co. Wildman, Harrold, Allen Dixon, of Chicago (Max E. Wildman, James P. Dorr and Kay L. Schichtel, of counsel), for appellee Medical Protective Co. Wayne A. Lenczycki, of Skokie, and Thomas G. Baffes and Richard J. Daley, both of Chicago, for amicus curiae Protective Medical Association of Illinois. Burditt and Calkins, of Chicago (Richard E. Favoriti, Tom Scheuneman and Michael V. Hasten, of counsel), for amici curiae Illinois State Medical Society and Jerry M. Ingalls.

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