Saipan, CNMI – The Supreme Court has issued a landmark ruling in Maratita v. CHCC, declaring unconstitutional two damages caps from the Government Liability Act and the Injury Compensation Act This decision significantly impacts the rights of individuals seeking compensation for injuries caused by negligence.
The case involved two separate plaintiffs who experienced devastating medical outcomes in 2020. One plaintiff suffered severe, permanent injuries after a botched surgery at CHC. The other involved a child who sustained permanent brain damage due to alleged negligence during childbirth. Both plaintiffs challenged the constitutionality of laws limiting the amounts of damages they could recover.
The Court examined the Government Liability Act, which capped damages at $100,000 for claims against the government, and the Injury Compensation Act, which imposed a $300,000 limit on non-economic damages such as pain and suffering.
In its decision, the Court ruled that these caps violate the Equal Protection Clause of the Commonwealth Constitution. The Court applied a heightened rational basis review, and found that the damages caps fail to demonstrate a clear, factual connection between their stated purposes and their actual impacts. The Court found that the two damages caps were arbitrary and no longer justified by the conditions present when they were enacted decades ago.
The Court emphasized that while limiting government liability and stabilizing the insurance market were valid goals in the 1980s and early 2000s, there was no current evidence to support these justifications. The lack of legislative findings or updated data about the caps’ necessity further undermined their constitutionality. The Court clarified that, in order for a law to be found constitutional, the Legislature must provide factual findings to support the law’s purpose and show that it is not arbitrary.
As a result, the Court struck down both the $100,000 and $300,000 caps, allowing plaintiffs like those in this appeal to pursue full and fair compensation for their injuries. Both cases are reversed and remanded to the Superior Court for further pretrial proceedings. The full opinion can be read on the Law Revision Commission website: https://www.cnmilaw.org/pdf/supreme/2024-MP-10.pdf
2024-PR-025
FOR IMMEDIATE RELEASE
DECEMBER 31, 2024
This press release has been prepared by court staff for the convenience of the public. For further information, contact the Supreme Court at Supreme.Court@NMIJudiciary.gov
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