Friday, December 6, 2013

Bankers Life & Casualty Co. v. Crenshaw case brief

Bankers Life & Casualty Co. v. Crenshaw case brief summary
486 U.S. 71 (1988)


CASE SYNOPSIS
Appellant insurer sought review of the decision of the Supreme Court of Mississippi, which affirmed a jury award in favor of appellee insured in the amount of the policy plus punitive damages and assessed a penalty of 15 percent of the judgment pursuant to Mississippi's penalty statute, Miss. Code Ann. § 11-3-23 (Supp. 1987), in the insured's action against the insurer for damages as a result of the loss of his foot in an accident.

CASE FACTS
On appeal, the insurer alleged that the punitive damages award violated the Eighth Amendment, the Due Process Clause, and the Contract Clause and that Mississippi's penalty statute, Miss. Code Ann. § 11-3-23 (Supp. 1987), which required the insurer, as an unsuccessful appellant from a money judgment, to pay an additional penalty of 15 percent of the judgment violated the Equal Protection Clause of the Fourteenth Amendment.

DISCUSSION

  • The Court declined to address the insurer's constitutional challenges to the punitive damages award, holding that the insurer's general mention of the U.S. Constitution in the lower courts was not sufficient to preserve the issues and that comity and the need for a properly developed record on appeal weighed in favor of the Court's decision declining to address the issues. 
  • The Court addressed the insurer's challenge to Miss. Code Ann. § 11-3-23 (Supp. 1987) and held that the statute did not violate the Equal Protection Clause where the penalty was rationally related to the achievement of legitimate state interests, including discouraging frivolous appeals and conserving judicial resources, and was reasonably tailored to the state's legitimate ends.

CONCLUSION
The Court affirmed the state supreme court's judgment denying the insurer's challenge to Mississippi's penalty statute under the Equal Protection Clause of the Fourteenth Amendment.


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