## Facts

- A District teacher selected students from Highland High School to attend a debate tournament in California in November 2000.
- The teacher rented two minivans to transport the team; an assistant coach and District employee drove one vehicle.
- On the return trip in Utah, the assistant coach negligently lost control, and the minivan rolled multiple times.
- Two students died, and three students suffered serious injuries.
- The families and injured students asserted negligence claims against the District; the District conceded the employee acted within the scope of employment and accepted vicarious liability.
- The parties settled for $500,000, the then-applicable statutory aggregate limit on recovery against governmental entities under Utah Code § 63-30-34.
- In the settlement, plaintiffs released the District from liability beyond the cap but reserved the right to challenge the cap’s constitutionality.
- Plaintiffs then filed a separate action seeking to invalidate the cap under the Utah and U.S. Constitutions.

## Issues

1. Whether Utah Code § 63-30-34’s aggregate damages cap in suits against governmental entities violates Utah’s open courts clause (Utah Const. art. I, § 11).
2. Whether the cap violates Utah’s uniform operation of laws clause (Utah Const. art. I, § 24).
3. Whether the cap violates the Equal Protection Clause of the U.S. Constitution by treating victims of governmental negligence differently from victims of private negligence.
4. Whether the cap violates federal due process by arbitrarily limiting recovery.

## Decision

- The Utah Supreme Court affirmed summary judgment for the District.
- The court held plaintiffs did not show the damages cap was unconstitutional on its face or as applied.
- The court concluded the cap is a permissible legislative condition on the statutory waiver of sovereign immunity.
- The court rejected challenges under the Utah open courts and uniform operation clauses and under federal equal protection and due process.

## Legal Principles

- The legislature may waive sovereign immunity on specified terms, including limiting the amount recoverable against the government through a damages cap.
- Utah’s open courts clause is not violated merely because a statute limits recovery; the analysis asks whether the legislature abolished or unreasonably restricted an existing cause of action without an adequate substitute or sufficient justification.
- Where governmental liability is created by statute against a historical background of sovereign immunity, a statutory damages cap does not constitute the abolition of a preexisting common-law remedy.
- Damages caps that do not involve a suspect class or fundamental right are reviewed under rational-basis scrutiny for equal protection and Utah’s uniform operation clause; protecting public funds and enabling predictable budgeting are legitimate governmental purposes.
- Under deferential substantive due process review, a damages cap tied to limiting governmental exposure and preserving fiscal stability is not unconstitutional merely because it yields harsh results in severe, multi-claimant cases.

## Conclusion

The Utah Supreme Court upheld Utah’s aggregate damages cap for claims against governmental entities, ruling that limiting recovery as part of a statutory waiver of sovereign immunity does not violate Utah’s open courts or uniform operation guarantees, nor federal equal protection or due process.


Tindley v. Salt Lake City Sch. Dist., 116 P.3d 295 (Utah 2005)