Pinnick v. Cleary

Brief Fact Summary.

Pinnick (Plaintiff) claimed that a state no-fault statute unconstitutionally deprived his right to full recovery in tort.

Synopsis of Rule of Law.

A no-fault insurance statute that limits an award for pain and suffering is constitutional if it bears a rational relation to a legitimate legislative objective and provides a reasonable substitution for prior rights.

Facts.

Plaintiff was injured in an automobile accident. He claimed that the accident was caused by Cleary (Defendant), who was negligent. Plaintiff sued Defendant in common law, seeking damages above and beyond what was allowed by the Massachusetts no-fault statute. Defendant used the no-fault statute as an affirmative defense. Plaintiff then brought a bill in equity to the Supreme Judicial Court of Massachussetts, claiming that the statute unconstitutionally deprived him of “his right to full recovery in tort.”

Issue.

Is the no-fault insurance statute unconstitutional because it limits the amount that Plaintiff can recover in a suit for negligence?

Held.

No. Judgment for Defendant.
* The no-fault insurance statute provides Plaintiff with a prompt, fixed recovery in the amount of his most salient out-of-pocket expenses. In exchange, Plaintiff forfeits the possibility of recovering for pain and suffering, including mental suffering associated with injury except in certain specified categories of cases. The victim whose injury falls outside these categories and whose medical expenses is less than $500.00 cannot recover at all for pain and suffering.
* The no-fault insurance statute has not impaired a cause of action, which is on a higher more sacrosanct level than the ordinary common law cause of action. Plaintiff claimed that it had for two reasons: (1) the tort action has the statute of a vested property right; and (2) the function of the cause of action is to safeguard the fundamental right of personal security and bodily injury which, although not mentioned in the United States Constitution, is nonetheless protected by it. The court disagreed with Plaintiff and held that no person has a vested interest in any rule of law entitling him to insist that is shall remain unchanged for his benefit. Plaintiff has no cause to complain solely because his rights are not now what they would have been before the no-fault statute.
* The Legislature has not attempted to abolish the preexisting right of tort recovery and leave the automobile accident victim without redress. The statute has his substantive rights of recovery only in one respect.
* The no-fault statute is constitutional under the due process clause if: (1) it bears a rational relation to a legitimate legislative objective; and (2) provides a reasonable substitution for prior rights.
* As to the first prong, the court concluded that the statute did not deprive Plaintiff of his rights under the equal protection clause
* As to the second prong, the Court, relying heavily on New York Central R.R. v. White, held that the effect of the no-fault statute on motorists was to provide benefits in return for affected rights at least as adequate as those provide to New York employees in return for rights taken by the act in the White case. Although the no-fault insurance statute may have the effect of depriving Plaintiff of his damages for pain and suffering, the exchange of rights involved bears considerable resemblance to the statute in the White case.

Discussion.

No-fault automobile legislation is constitutional.