Webster v. Boyett

Webster v. Boyett

Opinion

 [**460]   [*191]  Fletcher, Presiding Justice.

We granted the writ of certiorari to determine whether evidence of a defendant's similar acts or omissions is relevant in determining liability for punitive damages and, if so, the proper procedure to be followed in handling the admission of the evidence. We hold that the trial court did not abuse its discretion when it prohibited evidence of a prior conviction during the liability phase of a bifurcated trial or when it refused to separate the issue of liability for punitive damages from the issue of compensatory damages. Because the court of appeals found both rulings were [***2]  an abuse of discretion, we reverse.

BACKGROUND

Lois W. Boyett was injured in an automobile accident and filed a personal injury action against Jesse C. Webster III, who pleaded guilty to driving under the influence in connection with the accident. The trial court bifurcated the trial based on O.C.G.A. § 51-12-5.1, the punitive damages statute, and granted Webster's motion in limine to exclude evidence of a prior DUI during the first phase of the trial on liability. At the end of that phase, the jury returned a verdict for Boyett and awarded her $ 7,500 in compensatory damages, but declined to award punitive damages. She appealed, contending that the trial court erred in disallowing evidence of Webster's prior DUI to support her claim of punitive damages.

The court of appeals reversed. ¹ It held that the trial court abused its discretion by excluding evidence of Webster's prior DUI during the liability phase of the trial. The court concluded that the relevance of the evidence to Boyett's claim for punitive damages outweighed any prejudice to Webster on the issue of liability in the underlying negligence action if proper limiting instructions were given. The court noted the [***3]  problem with the statutory requirement that liability for punitive damages must be bifurcated from the amount of punitive damages. "Excluding from the jury in the liability phase evidence of other acts of driving under the influence or other similar acts . . . might assure defendants a fairer trial on liability for the underlying  [*192]  negligence at issue, but doing so in a bifurcated trial virtually assures that plaintiffs are denied fair trials on liability for punitive damages." ² As a result, the appellate court concluded that trial courts should follow a trifurcated procedure in which the jury determines compensatory damages in the first phase, the propriety of punitive damages in the second phase, and the amount of punitive damages in the third. ³ Finding a second abuse of discretion based on the trial court's refusal to separate the issues of liability and damages for the underlying tort from liability for punitive damages, the court of appeals reversed.

 [***4]  BIFURCATED PROCEDURES

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