In American Bank & Trust Co. v. Community Hospital (1984) 36 Cal.3d 359, a plaintiff challenged the constitutionality of another ICRA provision, Code of Civil Procedure section 667.7, which permits defendants to pay "future damages" of $50,000 or more periodically over the course of time the plaintiff incurs the losses rather than in a lump sum at the time of judgment. (See Code Civ. Proc., 667.7; American Bank, supra, 36 Cal.3d at p. 364.) The plaintiff contended that the jury trial guarantee requires a jury to fix the amount of future damages and make special findings on any issue that may affect the structuring of a periodic payment schedule. (American Bank, supra, 36 Cal.3d at p. 375.) The court disagreed, holding that once the jury found the amount of future damages, the court's determination of a periodic payment schedule did not infringe upon the constitutional right to jury trial. (Id. at p. 36.) The court, quoting Jehl, supra, 66 Cal.2d at pp. 828-829, reasoned that the jury trial guarantee did not preclude the adoption of new procedures or limitations "better suited to the efficient administration of justice . . . if there is no impairment of the substantial features of a jury trial." (American Bank, supra, 36 Cal.3d at pp.375-376.) The court further confirmed that "a plaintiff has no vested property right in a particular measure of damages, and that the Legislature possesses broad authority to modify the scope and nature of such damages." (American Bank, supra, 36 Cal.3d at p. 368.) In sum, the plaintiff challenged MICRA's provision for periodic payments (Code Civ. Proc., 667.7), which not only requires the trial court to establish a payment schedule for "future damages" over $50,000, if requested by either party, but further provides that periodic payments for future damages other than for lost income cease on the death of the plaintiff (id., subds. (a)-(c)). Pointing out that under the common law, a malpractice plaintiff receives a full, lump-sum payment, the plaintiff in American Bank claimed her right to jury trial was impaired by the requirement that the trial court establish a periodic payment schedule. (American Bank, supra, 36 Cal.3d at pp. 374-375.) The California Supreme Court considered the "precise roles which the Legislature contemplated that the jury and court would play in the formulation of a periodic payment judgment" under section 667.7. In ruling that the statute did not infringe on the constitutional right to a jury trial, the Supreme Court concluded: "Section 667.7 should be interpreted to require the jury to designate the portion of its verdict that is intended to compensate the plaintiff for future damages. . . . Once the jury has designated the amount of future damages--and has thus identified the amount of damages subject to periodic payment-- . . . the court's authority under section 667.7, subdivision (b)(1), to fashion the details of a periodic payment schedule does not infringe on the constitutional right to jury trial." (American Bank & Trust, at p. 376.) The Supreme Court concluded that as long as the jury was the finder of fact as to the amount of future damages, the directive that the trial court fix the periodic payment schedule did not infringe on the right to jury trial. (Id. at pp. 376-377.) And while the court pointed out several times that MICRA limits periodic payments on the plaintiff's death, the court did not even remotely suggest this legislative proscription compromised the right to jury trial. (American Bank, at pp. 366, 374-378 & fn. 14.)