100 N.Y.2d 159 (2003)
CPLR Article 50-A requires strict adherence to its formula for structuring judgments in medical malpractice cases, even if the resulting payout exceeds the jury’s initial future damages award, unless the statute’s literal application leads to an absurd result.
Summary
In a medical malpractice case, the New York Court of Appeals addressed how to structure a judgment for future damages under CPLR Article 50-A. The defendant hospital argued that mechanically applying the statute resulted in a payout exceeding the jury’s intended award due to the plaintiff’s long life expectancy and significant future care needs. The Court rejected the hospital’s proposed alternative calculation, emphasizing that the statute’s clear language and prior precedents require dividing the total future damages by the number of years of payment and adding a 4% annual increase. The Court affirmed the lower court’s judgment, emphasizing the judiciary’s role in following the legislature’s directive, while urging the legislature to revisit the statute.
Facts
Samuel Desiderio sued New York Hospital for malpractice causing severe brain damage at birth. Samuel required a permanent tracheostomy and gastrostomy tube and suffered frequent seizures. The jury awarded damages, including significant amounts for future pain and suffering, equipment, medication, supplies, medical care, nursing care, and therapy. The hospital did not contest liability.
Procedural History
The Supreme Court structured the future damages judgment according to the plaintiff’s proposed methodology based on CPLR Article 50-A. The Appellate Division affirmed. The Court of Appeals granted leave to appeal and certified the question of whether the Supreme Court’s order was properly made.
Issue(s)
Whether the structured judgment provisions of CPLR Article 50-A should be applied literally, even if the resulting total payout to the plaintiff significantly exceeds the amount of future damages awarded by the jury.
Holding
Yes, because the statute clearly mandates how the annuity for future damages should be calculated, and the Court should not substitute its judgment for that of the legislature unless a literal application yields an absurd result.
Court’s Reasoning
The Court emphasized the specific statutory procedure in CPLR 5031(e) for structuring the annuity for future damages: dividing the remaining amount of future damages by the number of years of payment and adding 4% to each succeeding year’s payment. The Court rejected the hospital’s argument that this approach should be modified to align the total payout more closely with the jury’s intended award. The Court stated the statute is clear and does not allow for assumptions about how the jury arrived at its verdict or itemization on a per-year basis. The Court referenced Bryant v. New York City Health & Hosps. Corp., 93 NY2d 592 (1999), highlighting that the most direct way to effectuate the will of the Legislature is to give meaning and force to the words of its statutes. The Court also cited Schultz v. Harrison Radiator Div. Gen. Motors Corp., 90 NY2d 311 (1997), holding that a jury may consider an inflationary rate, even though the trial court must apply the 4% additur specified in CPLR 5031(e). The Court recognized the structured judgment provisions represent a balance of various interests, and that while the plaintiff may receive more than the jury award, this alone does not justify disregarding the statutory procedure. Several judges concurred, urging the legislature to revisit the statute to determine if its operation is achieving its intended purposes. Judge Rosenblatt emphasized that the application of Article 50-A, particularly after Schultz, can lead to awards far exceeding plaintiffs’ damages, and Judge Read suggested revisiting Schultz to eliminate potential double-counting for inflation.