St. Mary's Hospital, Inc. v. Phillipe

In St. Mary's Hospital, Inc. v. Phillipe, 769 So. 2d 961 (Fla. 2000), the Court considered, inter alia, whether the noneconomic damages cap in the arbitration provisions of the Medical Malpractice Act--which provides that "noneconomic damages shall be limited to a maximum of $250,000 per incident"--limits the aggregate recovery of all claimants with respect to a single incident or the individual recovery of each claimant. 769 So. 2d at 967. (quoting 766.207(7)(b), Fla. Stat. (1997)). Having determined that the legislative intent behind the Medical Malpractice Act was "to provide a mechanism for the prompt resolution of medical malpractice claims through mandatory presuit investigation and voluntary binding arbitration of damages and to provide substantial incentives to claimants and defendants to voluntarily submit their cases to binding arbitration," the Court concluded that the $250,000 limit applied to each individual claimant. Id. at 970. The Court reasoned that doing so promoted the intended "early resolution of medical negligence claims" by providing incentives for claimants, defendants, and liability insurers to voluntarily arbitrate damages. Id. The Court further noted that "were we to interpret the noneconomic damages cap to apply to all claimants in the aggregate, . . . such an interpretation would create equal protection concerns." Id. at 971. The Court reasoned that limiting the $250,000 per incident to an aggregate award would result in the disparate treatment of the deaths "of a wife who leaves only a surviving spouse . . . and of a wife who leaves a surviving spouse and four minor children." Id. at 972. The Court reasoned that the type of classification addressed in this case is purely arbitrary and unrelated to a true state interest. The Court clearly announced in Phillipe that aggregate caps or limitations on noneconomic damages violate equal protection guarantees under the Florida Constitution when applied without regard to the number of claimants entitled to recovery. This inherently discriminatory action and resulting invidious discrimination do not pass constitutional muster. The Court stated: "If we were to accept St. Mary's contention that the Legislature intended to limit noneconomic damages to $250,000 per incident in the aggregate, then the death of a wife who leaves only a surviving spouse to claim the $250,000 is not equal to the death of a wife who leaves a surviving spouse and four minor children, resulting in five claimants to divide $250,000. We fail to see how this classification bears any rational relationship to the Legislature's stated goal of alleviating the financial crisis in the medical liability industry. Such a categorization offends the fundamental notion of equal justice under the law and can only be described as purely arbitrary and unrelated to any state interest." Id. at 972.