Pinnick v. Cleary – Case Brief
Pinnick v. Cleary, 360 Mass. 1, 271 N.E.2d 592 (1971).
Facts: Pinnick (P) was injured in an automobile accident. Pinnick claimed that Cleary (D) caused the accident and had been negligent. Pinnick brought suit and sought damages that exceeded the maximum amount allowable under the Massachusetts no-fault statute. Cleary used the statute as an affirmative defense. P brought a bill in equity to the Massachusetts Supreme Judicial Court, claiming that the statute unconstitutionally deprived him of his right to full recovery in tort.
Issue: Is a no-fault statute that limits the amount of recovery unconstitutional?
Holding and Rule: No. A no-fault statute is not unconstitutional even if it limits the amount a party can recover in an automobile accident, provided that it bears a reasonable relation to a permissible legislative objective.
The court held that in this case the statute’s intent was to ensure that courts were not overcrowded. A negative aspect of this statute for injured parties is that one could possibly have won a greater amount in court were he to have a sympathetic judge or jury. The court held that the statute did not deprive a victim of any constitutional rights because it still entitled the victim to recover for his injuries. The statute was deemed necessary to eliminate crowded courts and to give some certainty to insurance rates and actions. The court held that this was a permissible legislative objective.
Disposition: Affirmed, for D.