Curtis Publishing Co. v. Butts

Brief Fact Summary.

Man sues publishing company for libel and is awarded extremely high punitive damages which the defendant challenges.

Synopsis of Rule of Law.

It is within the trial judge’s discretion to remit an exceedingly high judgement for punitive damages to an acceptable level or if she finds that the judgement was influenced by passion and prejudice, to order a new trial.

Facts.

Defendant Curtis published a libelous article in one of its Posts claiming that plaintiff Butts, the Athletic Director at the University of Georgia, rigged a game. At trial it was clear that Defendant Curtis knew the information was false but published it anyway. The jury entered a verdict for Plaintiff Butts in the amount of $460,000 in general damages and $3,000,000 in punitive damages. Defendant Curtis filed a motion for a new trial based on the size of the punitive damage award. The motion was granted on the condition that Plaintiff Butts failed to remit the portion of the award above $400,000. Plaintiff Curtis filed another motion for judgement notwithstanding the verdict which was denied. After Plaintiff Butts filed a remittitur and Defendant Curtis’ motion for a new trial was denied and a judgement for Butts in the amount of $460,000 was entered. Defendant Curtis again filed another motion for a new trial under FRCP 60 which was also denied. Defendant Curtis appealed.

Issue.

Is it within the trial judge’s discretion to remit an exceedingly high judgement for punitive damages to an acceptable level or, if she finds that the judgement was influenced by passion and prejudice, to order a new trial?

Held.

Yes, it is within the trial judge’s discretion to remit an exceedingly high judgement for punitive damages to an acceptable level or, if she finds that the judgement was influenced by passion and prejudice, to order a new trial. holding below is affirmed.

Dissent.

Justice Circuit Judge Rives

The original punitive damages award of $3,000,000 and the remitted award are both unconstitutional. The award violated Defendant Curtis’ Seventh Amendment rights. The trial judge gave no reasons as to why he believed the jury’s award was not based on prejudice, but it clearly was and therefore cannot be remedied through remittitur. Curtis’ motion for a new trial should be granted.

Discussion.

1. It is the trial judge’s responsibility to determine if punitive damages are appropriate and if they are, what the appropriate amount is.
2. If the damages are too high and the judge does not think that amount is influenced by passion or prejudice, the judge can reduce the amount to a reasonable level.
3. This reduction does not violate the Seventh Amendment right to jury trial.
4. In this case the trial judge found that punitive damages were warranted based on Defendant Curtis’ disregard for publishing false information.
5. After the jury rendered its verdict the trial judge believed that although the damages awarded were extremely high that the punitive damages awarded were not influenced by prejudice or passion which is why a new trial was not granted.
6. It was within the judge’s discretion to remit the damages without granting a new trial, and that is what he did.
7. Defendant Curtis had the chance to fully try its case and therefore the holding below is affirmed.