Cheatham v. Pohle

DICKSON, J.,

dissenting.

The punitive damages scheme enacted in 1995 sought to modify Indiana's common law regarding punitive damages by capping the maximum amount of a punitive damage award at three times the amount of compensatory damages or $50,000, whichever is greater, and by requiring seventy-five percent of the final award to be allocated for use by the Violent Crime Victims' Compensation Fund. Ind.Code §§ 34-51-3-5, -6. To facilitate these objectives, this scheme requires that the statutory cap and allocation be concealed from every jury considering a claim for punitive damages. I.C. § 34-51-3-8. There is no statutory requirement that the state pay any legal fees related to its share of the punitive damage award.

In declaring that the allocation required by Indiana Code § 34-51-3-6 does not constitute a taking of private property in violation of the Takings Clauses of our federal and state constitutions, the majority relies primarily upon its contention that punitive damage plaintiffs have no property right in a judgment awarding punitive damages. I disagree. A person's property interest in a judgment vests upon the entry of that judgment by the trial court, not upon the eventual payment of the judgment by the judgment debtor.

A judgment is a court's "final determination of the rights and obligations of the parties in a case." Bmack's Law DictioNary 846 (7th ed. 1999). A judgment for money is property. Wilson v. Brookshire, 126 Ind. 497, 506, 25 N.E. 131, 134 (1890); Haynes v. Contat, 643 N.E.2d 941, 943 (Ind.Ct.App.1994); Browning v. Walters, *478616 N.E.2d 1040, 1047 (Ind.Ct.App.1993). I agree with the majority that a plaintiff's prejudgment claim of punitive damages is not a property interest, but I contend that it becomes a vested property interest upon the entry of a final judgment. The constitutional limitations upon the power of the legislature to interfere with rights established by a judgment have long been protected:

It is not within the power of a legislature to take away rights [that] have been onee vested by a judgment. Legislation may act on subsequent proceedings, may abate actions pending, but when those actions have passed into judgment the power of the legislature to disturb the rights created thereby ceases.

McCullough v. Virginia, 172 U.S. 102, 123-24, 19 S.Ct. 134, 142, 43 L.Ed. 382, 390 (1898).

At the conclusion of the trial in this case, the jury here returned a verdict in favor of Doris Cheatham awarding her $100,000 in compensatory damages and $100,000 in punitive damages. The trial court thereafter entered judgment "in favor of the Plaintiff Doris Cheatham and against the Defendant Michael Pohle in the amount of Two Hundred Thousand ($200,000.00) Dollars." Record at 88. Upon this entry by the trial court, the judgment became the property of Doris Cheatham. I am convinced that Indiana's statutory punitive damage scheme, which attempts thereafter to confiscate this property at the point the judgment is paid, ineseapably violates the Takings Clauses in both the Fifth Amendment to the United States Constitution ("nor shall private property be taken for public use, without just compensation") and Article 1, Section 21, of the Indiana Constitution ("No person's property shall be taken by law").

Because I disagree with the majority's belief that Cheatham's judgment is not property, I likewise reject its resulting conclusion that the Indiana punitive damage statute does not violate the Uniform and Equal Taxation Clause, Article 10, Section 1 of the Indiana Constitution. With respect to the Cheatham's claim that the statutory scheme violates Article 1, Section 21, of the Indiana Constitution, which prohibits the State from demanding the particular services of her attorney without just compensation, I agree and would adopt the analysis and conclusions of Judges Najam, Sharpnack, and Riley of our Court of Appeals. Cheatham v. Pohle, 764 N.E.2d 272, 277-81 (Ind.Ct.App.2002).

RUCKER, J., concurs.