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

Summary

The court upheld the statutory $250,000 punitive-damages cap as applied to Taylor’s premises-liability claim, rejecting challenges based on the Georgia Constitution’s jury-trial, separation-of-powers, and equal-protection provisions. It held that Taylor did not show that the historical jury-trial right encompassed punitive damages for conduct consisting only of an entire want of care rather than intentional misconduct. On Devereux’s cross-appeal, the court concluded that evidence supported the punitive-damages and attorney-fee awards and that post-judgment interest properly ran from the jury verdicts.