Citation. Gryc v. Dayton-Hudson Corp., 297 N.W.2d 727, CCH Prod. Liab. Rep. P8688 (Minn. May 23, 1980)
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Brief Fact Summary.
The Plaintiff, Lee Ann Gryc (Plaintiff), suffered severe burns when her pajamas were ignited by an electronic stove. The jury found that the Defendant Riegel Textile Corporation (Defendant), the manufacturer of the material the pajamas were made of, was liable and awarded Plaintiff both compensatory and punitive damages.
Synopsis of Rule of Law.
Punitive damages are an appropriate remedy both to punish past conduct and prevent future conduct when a defendant has demonstrated reckless disregard.
Facts.
On December 8, 1980, the Plaintiff, 4 years of age, was clothed in pajamas made of a material known as flannelette. The flannelette was manufactured by the Defendant. It was untreated, but met the federal minimum standards of product flammability. On this date Plaintiff reached across the electronic stove to shut off a timer and her pajamas were instantly ignited. Plaintiff received severe burns over her upper body. The jury found for Plaintiff and awarded her both compensatory and punitive damages.
Issue.
Did the trial court err by allowing the jury to subject the Defendant to punitive damages?
Held.
No. Judgment affirmed.
* Defendant first contends that a reckless disregard standard was improperly applied in this case and that the burden of proof on the issue of punitive damages should have been one of clear and convincing evidence rather than a preponderance of the evidence. These arguments were not raised at trial or in Defendant’s post-trial motions, therefore, this Court holds that the trial court’s instructions cannot now be attacked.
* Defendant also contends that public policy considerations dictate against the award of punitive damages in this case. It argues that the potential for multiple plaintiffs may result in severe economic hardship and excessive admonition. This argument has been consistently rejected by courts and defendant’s wealth or property and degree to which it has been previously punished will be relevant in future actions.
* Defendant’s final contention is that there is no need for the deterrent of punitive damages in this case. It claims that the compensatory damages and loss of sales and reputation act as an adequate deterrent. But the Defendant was shown to have acted in reckless disregard to the public and a punitive damages award serves to deter it from acting n a similar manner in the future. Additionally, the punishment of past misconduct is another purpose of punitive damages, and is well served in this case.
Discussion.
Punitive damages are generally reserved for intentional, reckless, or willful misconduct. Merely negligent conduct is insufficient to justify punitive damages.
