Nevada's Tortured Tort Reform

In an effort to thwart a perceived "crisis" andlegislative interest. This time, in addition to the
based on fear concocted by media campaignscauses previously discussed, the Commission
designed to shift the focus from the real problem,stated, "the insurance industry is at least partially
the citizens of the State of Nevada passed aresponsible."
ballot initiative capping noneconomic damages inC. The Historical Solutions
medical malpractice actions. See NRS 41A.035.As far back as the 1976 Commission study,
This cap is unconstitutional under both thesolutions to the alleged crisis were being proposed.
provisions of the United States and NevadaOne of the proposed solutions included "tort
Constitutions. The courts should declare thereform." These reforms included limitation on jury
noneconomic damage cap unconstitutional.verdicts. Id. However, as early as this report, the
A. The Problemevidence suggested that statistical probability of
NRS 41A.035 and related provisions, collectivelyPlaintiff success was so low that any such
sometimes referred to as "tort reform" werelimitation would have almost no real impact on
enacted to address the perceived problem ofinsurance rates and availability. The 1976 bulletin
skyrocketing medical malpractice insurance ratesstates, "only 8 percent of all claims ever go to
coupled with the belief that such rates weretrial. Only 6 of that 8 percent go all the way to
either driving physician's out of practice, limitingverdict." Of those, only 17 percent were in favor
their practices, or completely leaving the State ofof Plaintiffs."
Nevada. The urgency of the need for action andD. The Twenty First Century Problem
the perception presented was that in some wayWith an historical perspective and understanding,
this problem was immediate and causallywe are brought to the instant crisis which lead to
connected to recent unreasonably high jurythe ultimate initiative enactment of NRS
verdicts creating losses for insurers which justified§41A.035, limiting noneconomic damages to
unreasonable rate increases for medical$350,00.00. The clear purposes behind this tort
malpractice insurance.reform movement included: (a) reducing medical
The "problem" is not a creature of the twentymalpractice insurance rates; (b) stabilizing the
first century that has recently morphed from ainsurance market and availability of that insurance;
single cell into a full blown tumor. Rather, theand (c) insuring the availability of medical care for
"problem" has existed for decades. For instance, inthe citizens of Nevada.
September 1976, the Legislative Commission ofNRS §41A.035 was introduced in 2003 as
the Legislative Counsel Bureau, State of NevadaSenate Bill 97, which tracked the initiative petition
published Bulletin No. 71-1, entitled "The Problem ofand potential ballot submission to the voters. The
Medical Malpractice Insurance." This bulletin grewlegislative history is replete with references to the
out of Senate Concurrent Resolution No. 21fact that the Senate Bill 97 and the ballot initiative
(1975), wherein the study was commissioned. Thelanguage were identical. Thus, while the legislature
Resolution states,itself did not enact NRS §41A.035, the
WHEREAS, There is a nationwide problem ofdiscussions before the legislature are informative
doctors and health care providers obtainingand relevant. On March 23, 2003, Dr. Manthei, an
malpractice insurance with many of the insuranceindividual whose name was synonymous with the
carriers getting out of malpractice coverage andinitiative petition, testified before the Senate
others increasing premiums by several hundredJudiciary Commission stating, "All we are saying is
percent; and...presently the number of cases and the amount
WHEREAS, The malpractice problem in Nevada isof the awards is making health care unaffordable."
presently in a state of transition with the exactOn March 5, 2003, Ms. Alice Molasky-Arman,
dimensions of a number of problems unclear;...TheCommissioner for the Division of Insurance for
bulletin found that the "so-called malpractice crisis"the State of Nevada addressed the Senate
began in the early 1970's, with the twin problemJudiciary Committee. She testified that between
of high costs of premiums and decreasing1999 and 2001, 296 of 552 claims filed closed with
availability of insurance.no indemnity payment. She further testified that
B. The Historical Causesin July 2002, there was a huge spike in the
It is important to have a general understanding ofnumber of claims filed. Id. Ms. Molasky-Arman
the "causes" of the alleged crisis in order tostated that the 2002 tort reforms did not cause
evaluate whether the proposed "solution" isinsurance rates to decrease. Both Lawrence
rationally related to the interest sought to beMatheis and Assemblywoman Buckley stated that
protected. In the 1976 Bulletin, the Commissionthe reforms would not cause insurance premiums
identified a number of potential causes. First, theto decline. At best, there was some hope that
Commission found that there was no one singlethe reforms would result in stabilization. Id.
"cause." Among the causes, the CommissionIn discussing the causes of insurance premium
included: (a) malpractice itself; (b) the media; (c)increases in Nevada, Ms. Molasky-Arman including
national litigiousness; (d) contingency fees; (e) thein those causes: (a) reinsurance; (b) the lack of
imposition of no fault insurance; (f) Stock marketcompetition among insurers; and (c) stock market
losses; (g) Inadequate underwriting; and (h) jurylosses. She did not include in her statement
verdicts.relating to causes jury verdicts and their impact
While these are not all of the causes, theyon rates.
represent the most frequently discussed.With the foregoing background of the alleged
However, the Commission did conclude that the"crisis", the citizens of the State of Nevada were
leading cause of the medical malpractice crisis wassubjected to a media blitz from both proponents
medical malpractice itself. A decade later, theand opponents of the ballot initiative. With the fear
Legislative Commission revisited the crisis,of unavailability of medical care driving their votes,
publishing a "Study of Insurance Against Medicalthe citizenry passed the legislation which embodied
Malpractice," Bulletin No. 87-18, LegislativeNRS §41A.035. It is now a confusing
Commission of the Legislative Counsel Bureau,contradictory mess to say the least. We will delve
State of Nevada, August 1986. (Addendum IV).into this problem in finer detail in our next EZINE
This bulletin recognized that between the yearsarticle, or you can write or email us and we will
1976 and 1983, nationally medical malpracticeprovide you with a list of possible solutions which
insurance rates rose only 51%. However, oncewe are currently taking on behalf of our medical
again the cycle flowed resulting in dramaticmalpractice clients.
increases in 1984 and 1985. Id. This again piqued