Williams v. Wilson

Patricia Wilson’s (plaintiff) car was hit in an intersection by a car driven by Teri Williams (defendant). Williams was arrested and criminally charged with driving under the influence (DUI), to which she later pleaded guilty. Wilson also filed a civil suit against Williams seeking compensatory and punitive damages. Williams challenged, arguing that Wilson had failed to satisfy the required elements of proof under Kentucky’s punitive-damages statute, KRS 411.184. Specifically, Williams argued that Wilson had failed to prove that Williams had been subjectively aware that driving while intoxicated could result in death or bodily harm to others. The trial court held that KRS 441.184 was unconstitutional because it violated the jural-rights doctrine codified in the Kentucky’s constitution by effectively eliminating the preexisting common-law right to obtain punitive damages for gross negligence. The jural-rights doctrine is a Kentucky-specific doctrine that prohibits the legislature from eliminating common-law rights that were in existence when Kentucky’s constitution was enacted. Applying the common-law punitive-damages standard, the trial court found that Williams was grossly negligent and awarded Wilson punitive damages. The trial court further noted that Wilson would not have been entitled to punitive damages under KRS 411.184 because there was no direct evidence presented that Williams had the requisite subjective awareness at the time of the accident. On appeal, the appellate court affirmed. Williams appealed to the Kentucky Supreme Court.