Murphy v. Hobbs

Brief Fact Summary.

Hobbs (Plaintiff) sued Murphy (Defendant) to recover damages and the jury instructions allowed for punitive damages.

Synopsis of Rule of Law.

Punitive damages may not be recovered in cases where a defendant may also be criminally prosecuted.

Facts.

Hobbs (Plaintiff) sued Murphy (Defendant) to recover damages for malicious prosecution and false imprisonment. The jury instructions allowed damages for the purpose of punishing Defendant.

Issue.

Can punitive damages be recovered in cases where a defendant may also be criminally prosecuted?

Held.

No, the Court held punitive damages cannot be recovered in such cases. The Court reversed.

Discussion.

The Court reasoned that allowing punitive damages would essentially be the same as criminally prosecuting a defendant twice. Plaintiffs are adequately compensated without punitive damages, so they would serve as a windfall.

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