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Mathias v. Accor Economy Lodging, Inc.

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Brief Fact Summary.

Defendant was found negligent in allowing bedbugs to injure the plaintiff, and now appeals an award of punitive damages.

Synopsis of Rule of Law.

Punitive damages are not based on the income of the defendant, but rather the harm suffered, and detterance goals of the court.

Points of Law - Legal Principles in this Case for Law Students.

The Supreme Court did not, however, lay down a 4-to-1 or single-digit-ratio rule — it said merely that there is a presumption against an award that has a 145-to-1 ratio.

View Full Point of Law

The plaintiffs rented a motel room from the defendants.  The defendants had many past issues with bedbugs, and the room the plaintiff stayed in had been designated unfit for rental until it was exterminated.  They negligently failed to exterminate it before renting it to the plaintiff, who were injured.  The court awarded damages, and punitive damages, from which the defendant appeals.


Was the award of punitive damages proper?


Yes, punitive damages were properly awarded.


The court found that the punitive damages were awarded appropriately.  The court reasoned that because the defendants were negligent, it was within the purview of the court to award punitive damages. They opined that there were some factors, such as the wealth of the defendant, that were not appropriate to consider, but concluded that courts are largely free to exercise their discretion with regard to punitive damages.

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