REID v. MORRIS

845 S.E.2d 590, 309 Ga. 230
CourtSupreme Court of Georgia
DecidedJune 29, 2020
DocketS20A0107
StatusPublished
Cited by10 cases

This text of 845 S.E.2d 590 (REID v. MORRIS) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
REID v. MORRIS, 845 S.E.2d 590, 309 Ga. 230 (Ga. 2020).

Opinion

309 Ga. 230 FINAL COPY

S20A0107. REID v. MORRIS et al.

BOGGS, Justice.

At about 5:00 p.m. on September 1, 2016, Lakenin Morris was

driving his older cousin Keith Stroud’s car when he collided with a

car driven by 18-year-old Alonzo Reid, sending Reid to the hospital.

Morris had been drinking with Stroud, and Stroud asked Morris to

drive his car and gave him the keys even though Morris was

obviously drunk and Stroud knew that Morris was drunk, did not

have a valid driver’s license, and had a habit of recklessness. Morris

later pled guilty to driving under the influence (DUI).

Reid sued Morris for negligence and Stroud for negligent

entrustment, and both were found liable for Reid’s injuries (Morris

by default and Stroud by summary judgment). In a bench trial, the

court awarded Reid more than $23,000 in compensatory damages,

which the court apportioned equally between the two defendants,

citing the current version of the apportionment statute, OCGA § 51- 12-33. See Ga. L. 2005, p. 1, §§ 12, 15 (requiring trier of fact to

apportion damages for causes of action arising on or after February

16, 2005, in cases to which the apportionment statute applies). The

trial court also found that Morris and Stroud acted while under the

influence of alcohol and further found, by clear and convincing

evidence, that they acted in a manner that showed willful

misconduct, malice, wantonness, and that “entire want of care which

would raise the presumption of conscious indifference to

consequences.” OCGA § 51-12-5.1 (b). The court ordered Morris to

pay $50,000 in punitive damages, the exact amount that Reid

requested.1

1 The punitive damages statute, OCGA § 51-12-5.1, says as follows:

(a) As used in this Code section, the term “punitive damages” is synonymous with the terms “vindictive damages,” “exemplary damages,” and other descriptions of additional damages awarded because of aggravating circumstances in order to penalize, punish, or deter a defendant. (b) Punitive damages may be awarded only in such tort actions in which it is proven by clear and convincing evidence that the defendant’s actions showed willful misconduct, malice, fraud, wantonness, oppression, or that entire want of care which would raise the presumption of conscious indifference to consequences. (c) Punitive damages shall be awarded not as compensation to a plaintiff but solely to punish, penalize, or deter a defendant. (d) (1) An award of punitive damages must be specifically prayed for in a complaint. In any case in which punitive damages are claimed, the trier of fact shall first resolve from the evidence produced at trial whether an award of punitive damages shall be made. This finding shall be made specially through an appropriate form of verdict, along with the other required findings. (2) If it is found that punitive damages are to be awarded, the trial shall immediately be recommenced in order to receive such evidence as is relevant to a decision regarding what amount of damages will be sufficient to deter, penalize, or punish the defendant in light of the circumstances of the case. It shall then be the duty of the trier of fact to set the amount to be awarded according to subsection (e), (f), or (g) of this Code section, as applicable. (e) (1) In a tort case in which the cause of action arises from product liability, there shall be no limitation regarding the amount which may be awarded as punitive damages. Only one award of punitive damages may be recovered in a court in this state from a defendant for any act or omission if the cause of action arises from product liability, regardless of the number of causes of action which may arise from such act or omission. (2) Seventy-five percent of any amounts awarded under this subsection as punitive damages, less a proportionate part of the costs of litigation, including reasonable attorney’s fees, all as determined by the trial judge, shall be paid into the treasury of the state through the Office of the State Treasurer. Upon issuance of judgment in such a case, the state shall have all rights due a judgment creditor until such judgment is satisfied and shall stand on equal footing with the plaintiff of the original case in securing a recovery after payment to the plaintiff of damages awarded other than as punitive damages. A judgment Reid also asked the trial court to order Stroud to pay $100,000

in punitive damages, but the court declined. The court ruled that, in

spite of its findings that Stroud acted while under the influence of

alcohol and engaged in conduct susceptible to punitive damages, it

could not order him to pay punitive damages as a result of the Court

debtor may remit the state’s proportional share of punitive damages to the clerk of the court in which the judgment was rendered. It shall be the duty of the clerk to pay over such amounts to the Office of the State Treasurer within 60 days of receipt from the judgment debtor. This paragraph shall not be construed as making the state a party at interest and the sole right of the state is to the proceeds as provided in this paragraph. (f) In a tort case in which the cause of action does not arise from product liability, if it is found that the defendant acted, or failed to act, with the specific intent to cause harm, or that the defendant acted or failed to act while under the influence of alcohol, drugs other than lawfully prescribed drugs administered in accordance with prescription, or any intentionally consumed glue, aerosol, or other toxic vapor to that degree that his or her judgment is substantially impaired, there shall be no limitation regarding the amount which may be awarded as punitive damages against an active tort-feasor but such damages shall not be the liability of any defendant other than an active tort-feasor. (g) For any tort action not provided for by subsection (e) or (f) of this Code section in which the trier of fact has determined that punitive damages are to be awarded, the amount which may be awarded in the case shall be limited to a maximum of $250,000.00. (h) This Code section shall apply only to causes of action arising on or after April 14, 1997. of Appeals’ interpretation of OCGA § 51-12-5.1 (f) in Capp v.

Carlito’s Mexican Bar & Grill # 1, Inc., 288 Ga. App. 779 (655 SE2d

232) (2007), and Corrugated Replacements, Inc. v. Johnson, 340 Ga.

App. 364 (797 SE2d 238) (2017). The trial court understood those

decisions to hold that in OCGA § 51-12-5.1 (f), “[t]he ‘active

tortfeasor’ means the DUI driver and this is the only person the

statute authorizes an award of punitive damages against.”

Reid argued in the trial court that OCGA § 51-12-5.1 (f), as so

interpreted, violates the provision of Paragraph XI (a) of Article I,

Section I of the Georgia Constitution that guarantees that “[t]he

right to trial by jury shall remain inviolate[.]” The trial court

expressly but summarily rejected Reid’s constitutional challenge to

OCGA §

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Bluebook (online)
845 S.E.2d 590, 309 Ga. 230, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reid-v-morris-ga-2020.