## Facts

- Massachusetts enacted a no-fault automobile insurance statute providing personal injury protection (PIP) benefits for specified economic losses regardless of fault and restricting tort recovery for pain and suffering unless statutory thresholds were met.
- Milton Pinnick, a Massachusetts motorist insured with PIP coverage, was injured in a Boston automobile accident and alleged Carl Cleary negligently caused the collision.
- Pinnick incurred about $115 in medical expenses and approximately $650 in lost wages, and he sought broader common-law tort damages including pain and suffering.
- Pinnick received prompt PIP payments for covered out-of-pocket losses but was barred from recovering tort damages for pain and suffering because his medical expenses did not meet the statute’s $500 threshold and no statutory exception applied.
- Pinnick challenged the statute as unconstitutional after Cleary raised the statute as a defense in Pinnick’s negligence action; Pinnick pursued declaratory relief, and the case was presented to the full court on reservation and report.

## Issues

1. Whether restricting pain-and-suffering recovery for certain automobile-accident victims unconstitutionally impairs a vested property right in a common-law tort cause of action in violation of due process.
2. Whether the statute’s threshold scheme for noneconomic damages violates equal protection or due process because the classification is arbitrary or lacks a rational relation to legitimate legislative objectives and does not provide a reasonable substitute remedy.

## Decision

- The Supreme Judicial Court of Massachusetts upheld the constitutionality of the no-fault statute.
- The court rejected the claim that the statute unconstitutionally abolished or impaired a vested right to an unchanged common-law tort remedy.
- The court held that limiting pain-and-suffering damages in minor-injury cases was permissible because the statute was rationally related to legitimate goals and provided a reasonable substitute by guaranteeing prompt payment of economic losses.
- Declaratory relief was denied, leaving the statutory limitation on Pinnick’s tort recovery operative.

## Legal Principles

- A person has no vested constitutional entitlement to the continued existence of any particular common-law rule; legislatures may prospectively modify or restrict common-law causes of action subject to constitutional limits.
- A no-fault automobile insurance scheme that restricts pain-and-suffering recovery is constitutional where it is rationally related to legitimate legislative objectives and supplies a reasonable substitute remedy for the curtailed portion of the prior tort remedy.
- Under rational-basis review, statutory classifications for noneconomic-damages thresholds are valid if not arbitrary or irrational and if the statutory compensation structure provides meaningful redress for covered losses.

## Conclusion

Massachusetts’ no-fault statute validly traded prompt, assured recovery of specified economic losses for limits on pain-and-suffering awards in minor-injury cases, and the court held that this prospective alteration of tort remedies satisfied due process and equal protection under rational-basis review.


Pinnick v. Cleary, 360 Mass. 1, 271 N.E.2d 592 (Mass. 1971)