New opinion—trial court erred in reducing punitive damages based on nominal-damages award

Jester v. Hutt—civil—partial affirmance—Hardiman

The Third Circuit today upheld a civil verdict in favor of a horse-boarding facility for breach of contract and defamation. The boarding facility had brought the claims against an owner of horses it had boarded, and the horse owner had countersued for negligence and related claims. The jury found for boarding facility and awarded compensatory and nominal damages plus $89,999 in punitive damages, which the trial court reduced to $5,500.

Both sides appealed, and the Third Circuit sided with the boarding facility. The court rejected the horse owner’s challenges to the verdict, and it vacated the trial court’s reduction of the punitives award. It held that precedent requiring proportionality between punitive damages and compensatory damages doesn’t apply to nominal damages, so the trial court erred in relying on the $1 nominal-damages award for defamation as a basis for slashing the jury’s punitives award.

Joining Hardiman were Porter and Cowen. Arguing counsel (not labeled as such in the opinion, but confirmed by the audio) were Gordon Einhorn of Thomas Thomas & Hafer for the horse owners and Mark Bradshaw of Stevens & Lee for the boarding facility.