Adamson v. Bicknell
Annotate this CaseKody Bicknell sought review of a court of appeals decision permitting Tammy Anderson to pursue punitive damages in her lawsuit against him after Bicknell rear-ended Adamson's vehicle at a train crossing. The punitive damages claim was based, in part, on Bicknell's drug use prior to the collision. Bicknell also appealed from the panel's decision permitting Adamson to submit medical bill write-offs to the jury. On the punitive damages issue, the Supreme Court (1) agreed with the panel's decision that the district court set a higher burden of proof for the punitive damages claim than statutorily necessary by requiring that Adamson provide what would amount to scientific evidence of Bicknell's impairment resulting from his consumption of drugs; (2) concluded that the panel erred in deciding the district court should have permitted Adamson to amend for punitive damages based on the evidence as the panel perceived it; and (3) remanded for rehearing on that issue and application of the proper legal standard. On the medical bill write-off question, the Court held that the court of appeals erred in reaching the merits because the issue was not preserved for appeal.
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