Pinnick v. Cleary
Massachusetts Supreme Court
271 N.E.2d 592 (Mass. 1971)
Pinnick (plaintiff) was injured in a car accident he claimed was solely caused by Cleary's (defendant) negligence, and sought both actual and pain-and-suffering damages, but Massachusetts's no-fault statute limited pain-and-suffering recovery unless a plaintiff's medical expenses exceeded $500 or fell within certain statutory exceptions. Because Pinnick's medical expenses didn't exceed that threshold and he didn't qualify for an exception, he was denied pain-and-suffering damages and appealed, arguing the statute deprived him of a vested property right to full tort recovery and violated his due process rights.
Whether a personal-injury-protection insurance scheme that provides limited damages for minor injuries regardless of fault, while limiting pain-and-suffering recovery subject to certain exceptions, deprives plaintiffs of a vested property right in violation of the Due Process Clause.