Taylor, Exr. v. the Devereux Foundation, Inc. (and Vice Versa)

Summary

The court upheld the statutory reduction of a $50 million punitive-damages verdict to $250,000, rejecting challenges based on Georgia's constitutional jury-trial, separation-of-powers, and equal-protection guarantees. Applying the historical jury-trial framework, the court held that although premises-liability claims existed before the relevant constitutional date and punishment damages existed in some historical cases, Taylor did not show that punitive damages were historically available for conduct amounting only to an entire want of care rather than intentional misconduct. The court also upheld the punitive-damages and attorney-fee awards and the nunc pro tunc judgments establishing post-judgment interest from the verdict dates.