Supervised Administration of the Estate of Inlow v. Inlow

MAY, Judge,

dissenting.

The majority would uphold the award to the estate of proceeds from the wrongful death settlement in an amount equal to the funeral and burial expenses, on the premise Ind.Code § 34-23-1-1 does not require “itemization” of wrongful death award proceeds. Because the statute undoubtedly requires such damages be categorized, if not “itemized,” I must respectfully dissent.

*739The majority, citing Ind.Code chapter 34-51-2, correctly notes the general rule that there is no requirement compensatory damage awards be itemized: “It would be illogical to impose an itemization requirement for wrongful death awards while no such requirement exists for other personal injury awards.” (Op. at 738.) But the statute specifically addressing wrongful death awards has exactly that effect, and it controls. When two statutes cover the same subject and one does so in general terms while the other does so in specific terms, the more specific statute will be applied. Lockard v. Miles, 882 N.E.2d 288, 290 (Ind.Ct.App.2008).

There is, obviously, no explicit “itemization” requirement in the wrongful death statute. But it is just as obvious that Ind.Code § 34-23-1-1 does require the amount of damages recovered for the category of “reasonable medical, hospital, funeral and burial expense” be measured and defined. Wrongful death damages

shall be in such an amount as may be determined by the court or jury, including, but not limited to, reasonable medical, hospital, funeral and burial expenses, and lost earnings of such deceased person resulting from said wrongful act or omission. That part of the damages which is recovered for reasonable medical, hospital, funeral and burial expense shall inure to the exclusive benefit of the decedent’s estate for the payment thereof The remainder of the damages, if any, shall, subject to the provisions of this article, inure to the exclusive benefit of the widow or widower, as the case may be, and to the dependent children, if any, or dependent next of kin, to be distributed in the same manner as the personal property of the deceased.

Ind.Code § 34-23-1-1 (emphasis added).

So, while the statute does not explicitly require “itemization” of the wrongful death award, it does require that the damages be categorized as either (1) medical, hospital, funeral, and burial expense-related or (2) all other damages. That this allocation is required is apparent from the provision that funds in the two different categories be distributed to different entities. Those damages in the first category go to the estate, and the damages in the second category go to the widow and dependent children. There is no way to direct the proceeds to those different entities as the statute requires without knowing the amount of damages within each category.

The parties to this settlement agreement apparently contemplated part of the recovery was for funeral and burial expenses, but there is no indication how much expense was contemplated. The parties, had they addressed it, might have thought the nearly $285,000 Anita spent did not represent the “reasonable” expense the statute calls for. Anita argues we cannot know whether any of the wrongful death award was for burial and funeral expenses, but that is quite unlikely. The Estate’s premise seems to be that whatever Anita actually paid necessarily represents the “reasonable” expense the statute contemplates, which premise seems inconsistent with the language of the statute.

The statute is explicit that funeral and burial expenses are, in this context, an estate obligation. The majority result burdens Anita with an expense (in the form of her loss of wrongful death benefits) the estate should incur. Our policy regarding wrongful death benefits generally favors distribution to the widow (here, Anita) and dependent child, and not to the estate:

Wrongful death damages do not become a part of the decedent’s estate and are not subject to the claims of decedent’s creditors. The clear policy in Indiana as expressed in the decisions and statutes *740is that recovery of damages in wrongful death actions is only for the purpose of compensating for the pecuniary loss of a surviving spouse or dependent caused by the death of the decedent and to reimburse death creditor beneficiaries. * * * * *
According to the Wrongful Death Statute only a dependent is entitled to lost earnings. If the [personal representative] were allowed to recover those damages which are intended to benefit dependents, those damages would be paid to persons not contemplated by the Wrongful Death Statute ... contrary to the intent of the legislature.... The purpose of the Wrongful Death Statute is to provide for dependents, not to punish someone who causes a wrongful death. To allow damages which would not go to a dependent who has suffered pecuniary loss from the death of a decedent would not serve the purpose of the statute, but would serve only to punish the appellant.

Thomas v. Eads, 400 N.E.2d 778, 783 (Ind.Ct.App.1980).

I would accordingly remand for the measurement and categorization of damages Ind.Code § 34-23-1-1 requires and for distribution consistent with that section.