Forklift Equipment Product Liability Complaint - Part 5

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The Severability Clause

12. The severability clause of Public Act 89-7 (section 990) is null and void in that the constitutional invalid provisions of the act are non severable from the remaining portions inasmuch as the various provisions of the act constitute an interdependent legislative package designed to be passed in its entirety rather than as separate pieces. The provisions of the act are so mutually connected with and dependent on each other, that the legislator intended them as a whole, and if all could not be carried into effect the legislature would not have an act to the residual.

13. That the text of the act provides evidence that sections 2-1115.1 (non economic damages limitation), 2-1117.1 (jury instructions), 2-1116 (definition of tort feasor), 2-1117 (a) (elimination of joint liability), 2-1117 (b) (escape hatch for healing our professionals from 2-1117 (a) and sections 2-2103, 2-2104, and 2-2106 are mutually connected with and dependent upon each other, as conditions, considerations or compensations for each other. That the members of the legislative were forced to adopt Public Act 89-7 as a legislative scheme against the “civil justice system” in its entirety. The members of the legislature were not given an opportunity to consider sections 2-2103, 2-2104, and 2-2106 on their individual merits, but instead were presented with Public Act 89-7 as a complete and unified package made up of co-defendant parts.

That inasmuch as it is not severable, the aforementioned provisions of Public Act 89-7 violate article IV section 8 of the Illinois Constitution because they failed to confined to one subject.

14. That the constitutionality of Part 21 of Public Act 89-7 renders the remaining provisions null and void, as Public Act 89-7 would be void in its entirety.

PRAY FOR RELIEF

WHEREFORE the plaintiff prays for the judgment as follows:

1. That the Court find that sections 2-2103, 2-2104, 2-2106 of Public Act 89-7 are unconstitutional, null and void;

2. That the Court find that the acts severability clause (section 990) is null and void, thereby rendering Public Act 89-7 void in its entirety.

3. That this Court waive the necessity of the plaintiff filing any bond or in the alternative, that it set a fair and reasonably cost bond for the plaintiff; and

4. That the Plaintiff have such other and further relief as the Court shall deem necessary and proper.

COUNT XV
COMPLAINT FOR DECLARATORY RELIEF AND TO OTHERWISE ENJOIN THE CONDUCT OF VARIOUS DEFENDANTS WITH REGARD TO SPECIFIC PROVISIONS OF PUBLIC ACT 89-7 AND SEPARATION OF POWERS, SPECIAL LEGISLATION, RIGHT TO TRIAL BY JURY, ACCESS TO THE COURTS, THE LACK OF RATIONAL BASIS, AND THE SEVERABILITY CLAUSE OF PUBLIC ACT 89-7.

NOW COMES the Plaintiff, VERNON BEST, by his attorneys, and complaining of the Defendants, Taylor, Allied, and Helms, and each of them, alleges as follows:

1. The Plaintiff repeats, realleges and incorporates by reference Count I - VIII as if fully set forth herein.

2. That Sections 2-1003, 2-1007.1, 2-1115.1, 2-1116, 2-1117, and 2-2103, 2-2104, 2-2106, 8-802, 8-2001 and 8-2003 of the Illinois Code of Civil Procedure, and Sections 3.5 and 5 of the Illinois Joint Tortfeasor Contribution Act are also unconstitutional insofar as they are a nonseverable part of Public Act 89-7, which is void as a whole under the Illinois Constitution.

Interrelationship of the Parties

3. That the circumstances surrounding the Plaintiffs injuries give rise to a cognizable cause of action against the Defendants Taylor, Helms, and Allied, and each of them, under the common law of Illinois.

4. That the Plaintiff has filed a Complaint at Law against said Defendants in the Circuit Court, Third Judicial Circuit, Madison County, Illinois (Law Division), Counts I - VIII herein, alleging a cause of action arising under the common law, which will require the jury, pursuant to Section 2-1117 of the Illinois Code of Civil of Procedure, to make various allocations of fault in order to determine the proper share of liability of each Defendant, Plaintiff's employer, or any other person who may be deeded a “tortfeasor” as defined in Section 2-1116 of the Illinois Code of Civil Procedure.

5. That notwithstanding the existence of Section 2-1117 and the fact that contribution is inherently irreconcilable with several liability, under Public Act 89-7 the circumstances surrounding Plaintiff's injuries gives rise to a cognizable claim by the named Defendants and make it likely that they will claim contribution against Laclede Steel under the Illinois Joint Tortfeasor Contribution Act ( 740 ILCS 100/1 -5).

6. That it is likely that the Plaintiff's employer, Laclede Steel, will be found to be at least one percent (1%) at fault of the injuries sustained by Plaintiff.

Separation of Powers

7. That Sections 2-1003, 8-802, 2-1107.1, 2-1115, 2-1116 and 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act constitute a complete an systematic abrogation of the judicial powers conferred upon the Illinois judicial branch by Article VI, Section 1 of the Constitution of the State of Illinois. This directly infringes upon the inviolate authority of the Supreme Court of Illinois, which is a violation of the Separation of Powers between the legislative judicial branches of the government of the State of Illinois as articulated in Article II, Section 1 and Article IV, Section 1 of the Illinois Constitution, inasmuch as these provisions attempt to legislatively vitiate numerous, well-reasoned decisions of the Appellate and Supreme Courts of the State of Illinois. Indeed, the Act systematically reversed more than 70 decisions of the Illinois Supreme Court and Appellate courts.

Special Legislation

8. That Sections 2-1003, 8-02, 2-1007.1, 2-1115.1, 2-1116 and 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act are special laws where a general law could instead have been made applicable in violation of Article IV, Section 13 of the Illinois Constitution against special legislation.

9. That a meaningful policing of the limitations on special legislation should be left to the courts.

10. That the special “escape hatch” for defendants in a medical malpractice cause of action found in Section 2-1117(b) renders the entire act void as violative of Article IV, Section 13 of the Illinois Constitution. The “escape hatch” provided a quid pro quo so that Public Act 89-7 could be passed in its entirety.

Right to Trial by Jury

11. That Sections 20-1115.1 and 2-1107.1 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act violate Article I, Section 13 of the Illinois Constitution, which guarantees that the right of trial by jury as heretofore enjoyed shall remain inviolate. These sections deny the Plaintiff the right to trial by jury inasmuch as they require the jury be given false information, require that necessary information be withheld from the jury, deny the Plaintiff full and complete compensation, and promote sham trials.

Access to the Courts

12. That, in addition to the lack of rational basis identified in Count's XII and Count XIII, Section 2-1007.1, 2-1115.1, 2-1116, 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 an 5 of the Joint Tortfeasor Contribution Act lack a rational basis for any legitimate governmental purpose for one or of more of the following reasons:

a. tort cases comprise a small fraction of all civil cases filed in Illinois;

b. The available objective evidence unequivocally demonstrates that the number of tort filings in Illinois has decreased in the last eight years; this reduction in filings demonstrates that there is no crises in the civil justice system relating to tort cases requiring massive restrictions in the tort system;

c. there is no lack of available liability coverage for products and services in the present market, nor has there been such an availability problem in the last ten years; there is no evidence of vastly increased insurance premiums, and no evidence to suggest that there is any “insurance crises” in Illinois.

d. experience has shown that where a wrongdoer calculates that the cost of defending an action and paying any settlements or awards is less than the profit to be made from marketing an unsafe product or engaging in an unsafe practice, the wrongdoer will be more likely to engage in the unsafe practice;

e. objective studies show that the Illinois economy is growing at a faster rate that the nation as a whole; additionally, unemployment in Illinois is below the national average, construction is growing at seven times the national rate, and large employers continue to invest in Illinois;

f. the public believe strongly in preserving a civil justice system and the concept of full compensation for injuries caused by wrongdoers.

g. damage awards for injuries caused by wrongful conduct deter future wrongful conduct; the arbitrary restriction of damage awards encourages future carelessness;

h. no scientific, objective or empirical studies have shown any economic benefits that follow restrictions on the civil justice jury system; there is no objective evidence to show that the civil justice system which currently exists negatively impacts Illinois job creation, job retention, health care costs, or insurance costs;

i. when an insured plaintiff is unable to collect all of his damages through the tort system, that person will become a burden to the taxpayers of the State of Illinois.

j. there is no justification to invade and usurp powers entrusted to the citizens, jurors and judicial branch of this State because:

1. fault remains the basis of tort liability;

2. injured persons should be ensured that they will continue to be fully and fairly compensated for all of their losses legally caused by the wrongdoer;

3. the judicial system does, and will continue to, guarantee that adequate parameters exist for the review of non-economic and punitive damages;

4. Public Act 89-7 will increase the costs of the tort system because it will discourage the settlement of meritorious claims;

5. the present system strikes a fair balance between the rights of injured persons and the protections afforded to wrongdoers; and

6. the present system provides an appropriate incentive for a potential wrongdoer to act safely and reasonably for the protection for Illinois citizens from injury and death.

The Severability Clause

13. That the severability clause of Public Act 89-7 (Section 990) is null and void in that the constitutionally invalid provisions of the Act are nonseverable from remaining portions inasmuch as the various provisions of the Act constitute an interdependent legislative package designed to be passed in its entirety rather than as separate pieces. The provisions of the Act are so mutually connected with and dependent on each other, that the legislature intended them as a whole, and if all could not be carried into effect the legislature would not have enacted the residual.

14. That the text of the Act provides evidence that Sections 2-1115.1 (noneconomic damages limitation), 2-1107.1 (jury instructions), 2-1116 (definition of tortfeasor), 2-1117(a) (elimination of joint liability), and 2-1117(b) (escape hatch for healing art professionals from 2-1117 (a)) are mutually connected with and dependent on each other, as conditions, considerations or compensations for each other.

15. That members of the legislature were forced to adopt Public Act 89-7 as a legislative scheme against the “civil justice system” in its entirety. Members of the legislature were not given an opportunity to consider Sections 2-1003, 8-802, 2-1107.1, 2-1115, 2-1116 and 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act on their individual merits, but instead were presented with Public Act 89-7 as a complete and unified package made up of co-dependent parts.

16. That, inasmuch as it is not severable, the aforementioned provisions of Public Act 89-7 violate Article IV, Section 8 of the Illinois Constitution because they fail to be confined to one subject.

17. That the unconstitutionality of any one of the aforementioned provisions renders the remaining provisions null and void, as Public Act 98-7 would be void in its entirety.

PRAYER FOR RELIEF

WHEREFORE, the Plaintiff prays for judgment as follows:

1. That the Court find that Sections 2-1003, 8-802, 2-1107.1, 2-1115.1, 2-1116 and 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act, and each of them, are unconstitutional, null and void;

2. That the Court find that Sections 2-1003, 8-802, 2-1107.1, 2-1115.1, 2-1116 and 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act violate the Separation of Powers doctrine enumerated in Article II, Section 1 of the Illinois Constitution.

3. That the Court find that Sections 2-1003, 8-802, 2-1107.1, 2-1115.1, 2-1116 and 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act are special laws where a general law cold have been made applicable in violation of Article IV, Section 13 of the Illinois Constitution.

4. That the Court find that Sections 2-1107.1 and 2-1115.1 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act deny the Plaintiff his right to trial by jury in violation of Article I, Section 13 of the Illinois Constitution ;

5. That the Court find that Sections 2-1003, 8-802, 2-1107.1, 2-1115.1, 2-1116 and 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act deny the Plaintiff his right to a remedy in violation of Article I, Section 12 of the Illinois Constitution.

6. That the Court find that Sections 2-1003, 8-802, 2-1107.1, 2-1115.1, 2-1116 and 2-1117, 2-2103, 2-2104, 2-2106 of the Illinois Code of Civil Procedure and Sections 3.5 and 5 of the Joint Tortfeasor Contribution Act lack any rational basis to any legitimate governmental purpose;

7. That the Court find that the Act's severability clause (Section 990) is null and void;

8. That this Court waive the necessity of the Plaintiff's filing any bond, or in the alternative, that it set a fair and reasonable cost bond for the Plaintiff; and

9. That the Plaintiff have such other and further relief as the Court shall deem necessary and proper.

COUNT XVI
COMPLAINT FOR DECLARATORY RELIEF AND TO OTHERWISE ENJOIN THE CONDUCT OF VARIOUS DEFENDANTS WITH REGARD TO PUBLIC ACT 89-7 IN ITS ENTIRETY.

NOW COMES the Plaintiff, Vernon Best, by and through his attorneys, CARLSON, WENDLER & SANDERSON, THE LAW OFFICES OF CHARLES R. ABELE, and PITTS, DUGAN & DIAZ, and complaining of the Defendants, Taylor, Allied, and Helms, and each of them, alleges as follows:

1. The Plaintiff repeats and realleges and incorporates by reference Counts I through IX as if fully set forth herein.

Interrelationship of Parties

2. That the circumstances surrounding the Plaintiffs injuries give rise to a cognizable cause of action against Taylor, Allied and Helms, and each of them, under the common law of Illinois.

3. That the Plaintiff has filed a Complaint at Law against said Defendants in the Circuit Court of Madison County, Illinois, Count I herein, alleging a cause of action arising under the common law, which will require the jury, pursuant to Section 2-1117 of the Illinois Code of Civil Procedure, to make various allocations of fault in order to determine the proper share of liability of each Defendant, Plaintiff's employer, or any other person who may be deemed a “tortfeasor” as defined in Section 2-1116 of the Illinois Code of Civil Procedure.

4. That notwithstanding the existence of Section 2-1117 and the act that contribution is inherently irreconcilable with several liability, under Public Act 89-7 the circumstances surrounding Plaintiff's injuries gives rise to a cognizable claim by the named Defendants and make it likely that they will claim contribution against Laclede under the Illinois Joint Tortfeasor Contribution Act ( 740 ILCS 100/1 -5).

5. That it is likely that the Plaintiffs employer, Laclede, will be found to be at least one percent (1%) at fault for the injuries sustained by Best.

UNCONSTITUTIONAL CHARACTERISTICS OF PUBLIC ACT 89-7 IN ITS ENTIRETY.

6. That the severability clause of Public Act 89-7 (Section 990) is null and void in that the constitutionally invalid provisions of the act are nonseverable from the remaining portions inasmuch as the various provisions of the Act constitute an interdependent legislative package designed to be passed in its entirety rather than as separate pieces. The provisions of the Act are so mutually connected with and dependent on each other that the legislature intended them as a whole, and if all could not be carried into effect the legislature would not have enacted the residual.

7. That the text of the Act provides evidence that Sections 2-1115.1 (noneconomic damages limitation), 2-1107.1 (jury instructions), 2-1116 (definition of tortfeasor), 2-1117(a) (elimination of joint liability), and 2-1117(b) (escape hatch for healing art professionals from 2-117(a)) are mutually connected with and dependent on each other, as conditions, considerations or compensations for each other.

8. That members of the legislature were forced to adopt Public Act 89-7 as a legislative scheme against the “civil justice system” in its entirety. Members of the legislature were not given an opportunity to consider any of the provisions on their individual merits, but instead were presented with Public Act 89-7 as a complete and unified package made up of codependent parts.

9. That, inasmuch as it is not severable, Public Act 89-7 violates Article IV, Section 8 of the Illinois Constitution because it fails to be confined to one subject.

10. Accordingly, that the unconstitutionality of any one of the provisions in the Act renders the remaining provisions null and void, and renders Public Act 89-7 void in its entirety.

Special Legislation

11. That each of the Act's provisions could have been made applicable to tort law generally. However, each provision almost exclusively applies to personal injury and property damage torts. There is no basis for this restricted scope to select types of torts.

12. That Public Act 89-7, considered in its entirety, is a special law where a general law could instead have been made applicable. The legislature only had the power to pass provisions that were generally applicable to all tort cases. Thus, Public Act 89-7 violates Article IV, Section 13 of the Illinois Constitution against special legislation.

13. That a meaningful policing of the limitations on special legislation should be left to the courts.

14. That the special “escape hatch” for defendants in a medical malpractice cause of action found in Section 2-1117(b) renders the entire act void as violative of Article IV, Section 13 of the Illinois Constitution. The “escape hatch” provide a quid pro quo so that Public Act 89-7 could be passed in its entirety.

Separation of Powers

15. That Public Act 89-7, considered in its entirety, constitutes a complete and systematic abrogation of the judicial powers conferred upon the Illinois judicial branch by Article VI, Section 1 of the Constitution of the State of Illinois. This directly infringes upon the inviolate authority of the Supreme Court of Illinois, which is a violation of the Separation of Powers between the legislative and judicial branches of the government of the State of Illinois as articulated in Article II, Section 1 of the Illinois Constitution, inasmuch as the bill contains various provisions that attempt to legislatively vitiate numerous, well-reasoned decisions of the Appellate and Supreme Courts of the State of Illinois. Indeed, the Act systematically reversed more than 70 decisions of the Illinois Supreme Court and Appellate courts.

Lack of Rational Basis

16. That Public Act 89-7, considered in its entirety, lacks a rational basis for any legitimate governmental purpose for one or more of the following reasons:

a. the current civil justice system consistently and fairly compensates injury victims as determined by the facts and evidence of each case rather than utilizing an unreasonable and arbitrary predetermination;

b. the Illinois civil justice system, through its citizenjurors and the judicial branch with its use of its power of remittitur when necessary, fairly and accurately assures the fairness of jury awards;

c. the available evidence shows that in recent years that there has been no significant increase in the average size of the verdicts, nor has there been any significant increase in the percentage of verdicts for injured citizens; therefore there is no plausible reason to suggest that the juries in Illinois are “out of control” or that the civil justice system is in need of drastic change;

d. the existing public policy in Illinois is that liability for damages shall be based on fault, and that were proven, that wrongdoers shall be held fully accountable for all harms caused;

e. an innocent plaintiff should not be required to bear the risk of non-collection when one or more of the wrongdoers is unable to pay its proportionate share of damages; the burden of the shortfall in collection has been placed on the wrongdoers in Illinois common law for more than one century;

f. Illinois common law has always recognized that non-economic losses are no less important than out-of-pocket expenses; it has always been the public policy of the State of Illinois that an injured party is entitled to fair and complete compensation for all losses suffered by the wrongful act of another, including non-economic losses;

g. the consistent application of existing jurisprudence provides individualized, fair and complete damage awards which are just and benefit all parties and society;

h. there is more than a century of jurisprudence in Illinois for courts to rely upon in assessing and reviewing non-economic damages; non-economic damages are individualized and depend entirely on the facts in evidence presented to a trier of fact subject to trial, Appellate and Supreme Court review;

i. the judicial branch is empowered to, and is perfectly capable of, monitoring and controlling jury verdicts which may be perceived to be excessive;

j. the judiciary balances the rights of injured persons and legitimate protections for wrongdoers, with the goal of achieving justice in every case;

k. the majority of states (including Iowa and Kentucky, which border Illinois) do not impose arbitrary and unreasonable limits on non-economic damages;

l. there is no scientific basis for concluding that damages for pain, suffering, disability, disfigurement, loss of society and loss of consortium of the injured party are any more difficult for the jury to determine than those for economic loss;

m. tort cases comprise a small fraction of all civil cases filed in Illinois;

n. the available objective evidence unequivocally demonstrates that the number of tort filings in Illinois has decreased in the last eight years; this reduction in filings demonstrates that there is no crisis in the civil justice system relating to tort cases requiring massive restrictions in the tort system;

o. there is no lack of available liability coverage for products and services in the present market, nor has there been such an availability problem in the last ten years; there is no evidence of vastly increased insurance premiums, and no evidence to suggest that there in any “insurance crisis” in Illinois;

p. experience has shown that where a wrongdoer calculates that the cost of defending an action and paying any settlements or awards is less than the profit to be made from marketing an unsafe product or engaging in an unsafe practice, the wrongdoer will be more likely to market the unsafe product or engage in the unsafe practice;

q. per capita health costs have grown slower in Illinois than in most states that have imposed limitations on jury verdicts;

r. between 1980 and 1991, Illinois saw the slowest growth in aggregate health care spending of all 50 states and the District of Columbia;

s. health care availability problems, if they exist, are due to factors unrelated to the tort system;

t. objective studies show that the Illinois economy is growing at a faster rate than the nation as a whole; additionally, unemployment in Illinois is below the national average, construction is growing at 7 times the national rate, and large employers continue to invest in Illinois;

u. the public believes strongly in preserving a civil justice system and the concept of full compensation for injuries caused by wrongdoers;

v. damage awards for injuries caused by wrongful conduct deter future wrongful conduct; the arbitrary restriction of damage awards encourages future carelessness;

w. no scientific, objective or empirical studies have shown any economic benefits that follow restrictions on the civil justice jury system; there is no objective evidence to show that the civil justice system which currently exists negatively impacts Illinois job creation, job retention, health care costs, or insurance costs;

x. available evidence shows that in these states that limit non-economic damages, employment, health care costs, availability of health care and the costs of consumer do not improve;

y. there are no objective studies to indicate that limits on non-economic damages will improve health care in rural Illinois; no state that has imposed restrictions on jury verdicts has seen an improvement in rural health care availability;

z. a limitation on non-economic damages will deny injured persons recovery for their full economic losses;

aa. limiting non-economic damages will discourage settlements since the defendants will have little incentive to settle even the most catastrophic cases;

bb. when an injured plaintiff is unable to collect all of his damages through the tort system, that person will become a burden to the taxpayers of the State of Illinois; and

cc. there is no justification to invade and usurp powers entrusted to the citizens, jurors and judicial branch of this State because;

1. fault remains the basis of tort liability;

2. injured persons should be ensured that they will continue to be fully and fairly compensated for all of their losses legally caused by the wrongdoer

3. the judicial system does, and will continue to, guarantee that adequate parameters exist for the review of non-economic and punitive damages;

4. Public Act 89-7 will increase the costs of the tort system because it will discourage the settlement of meritorious claims;

5. the present system strikes a fair balance between the rights of injured persons and the protections afforded to wrongdoers; and

6. the present system provides an appropriate incentive for a potential wrongdoer to act safely and reasonably for the protection for Illinois citizens from injury and death.

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