A court was correct to limit the amount of damages awarded to a bus driver injured following a crash involving a Metro vehicle, the Missouri Supreme Court has ruled.
Plaintiff Mary J. Moore appealed from a St. Louis City Circuit Court decision to cut the $1.878 million jury award to statutory maximum for public entities covered by sovereign immunity.
In 2020, the cap for any one person in a single accident or occurrence is $435,849, according to the Missouri Department of Insurance.
Moore argued the trial court Judge Christopher E. McGraugh erred because he should have based his decision on federal regulations because the Bi-State Development Agency, which manages the Metro, is a dual state entity and engages in interstate commerce.
Under Federal Motor Carrier Safety Regulations a minimum level of financial responsibility, that is insurance coverage, must be “maintained by for-hire motor carriers of passengers operating motor vehicles in interstate … commerce.” That level is coverage of up to $5 million.
"The mere proposition that Metro must maintain a minimum level of financial responsibility as set forth by federal safety regulations does not conflict with the legislature’s per individual, per-occurrence statutory limitation of liability, nor does it implicitly overrule that limitation," Chief Justice George W. Draper wrote in an opinion filed Sept. 15 with the entire panel concurring.
He added: "There is no need to engage in additional statutory construction because the statutes’ plain language is clear and there is no statutory conflict.
"The circuit court’s judgment, which reduced Driver’s damage award to statutory maximum amount allowed, plus interest, is affirmed."
The underlying action centers on an April 19, 2013 incident when Moore was driving a scheduled bus route, which involved picking up children before school.
"When she arrived at an intersection in the City of Saint Louis, the student who is picked up at that intersection was not waiting for her," according to the Supreme Court's retelling.
"Driver parked the school bus and turned on its flashers. The student arrived and boarded the bus. After the student safely boarded the bus, a Metro Call-A-Ride bus collided with driver's school bus."
Following a trial, the jury awarded more than $1.8 million in damages. Metro filed a motion calling for a reduction to the maximum amount allowed under Missouri legislation covering public entities and sovereign immunity. This was granted.
The plaintiff appealed, arguing that the state law conflicts with the federal regulations. She unsuccessfully argued the reduction was improper and that the original award be reinstated.