Knowles v. United States
South Dakota Supreme Court
544 N.W.2d 183 (1996)
Twelve-day-old Kris Knowles was hospitalized at Ellsworth Air Force Base for a fever; nurses' aides recorded his steadily declining temperature overnight but never alerted a nurse or physician. Kris developed hypoglycemia and suffered respiratory arrest, causing severe, permanent brain damage. His parents (plaintiffs) sued the United States (defendant) in federal court for malpractice, emotional distress, and loss of consortium. The government admitted liability but invoked South Dakota's $1 million cap on medical-malpractice damages. The Eighth Circuit certified several questions to the South Dakota Supreme Court, principally whether the cap violated the state and federal constitutions.
Whether South Dakota's statutory cap on damages recoverable in a medical-malpractice action violates the state constitution's guarantee of a jury trial or its due-process clause.