Citation Numbers: 516 A.2d 701, 512 Pa. 322
Judges: Flaherty, Hutchinson, Larsen, McDERMOTT, Nix, Papadakos, Zappala
Filed Date: 10/23/1986
Status: Precedential
Modified Date: 8/7/2023
OPINION OF THE COURT
Doris Lyles was rendered a quadraplegic when she was injured in an automobile accident on March 11, 1979 on the Schuylkill Expressway in Philadelphia. The accident occurred when the automobile in which she was riding struck a pool of water on the road. In the lawsuit that followed, Ms. Lyles sued the Department of Transportation of Pennsylvania, which had designed the highway and was respon
A jury found against the Commonwealth and awarded Ms. Lyles $750,000; but the jury returned a verdict in favor of the additional defendants, the City and the driver. Ms. Lyles then moved to mold the verdict to add damages for delay pursuant to Pa.R.C.P. 238, and the Commonwealth moved, inter alia, to mold the verdict pursuant to the $250,000 limitation of liability required by the Limitations on Damages provision of the Sovereign Immunity Act, currently found at 42 Pa.C.S.A. § 8528.
The issues on this appeal are whether the statutory limitation of damages recoverable against the Commonwealth is constitutional under the Pennsylvania and United States Constitutions. In particular, at issue is whether this limitation on damages violates Article III, Section 18 of the Pennsylvania Constitution, and, secondly, whether it violates the Equal Protection provision of the United States Constitution and Article III, Section 32 of the Pennsylvania Constitution.
. At the time of the accident, the applicable statute was Section 511 of the Judicial Code, formerly 42 Pa.C.S. § 5111. Section 5111 was repealed by the Act of October 5, 1980, P.L. 693, 42 Pa.C.S.A. 8528, which is the current codification of the statute.
. We note that Commonwealth Court upheld the Sovereign Immunity Act against an Equal Protection challenge on an “any-rational-basis” analysis. Since, in our view, an important right is involved, the “heightened” level of scrutiny, not the any-rational-basis test is the appropriate standard of review. As in Smith, even under the more stringent test, the statute passes constitutional muster, for it implicates an important governmental interest — protecting the public treasury against large and unpredictable tort recoveries — which is implemented by a classification closely related to that interest.