Brandy v. Flamboyant Investment Co.

MEMORANDUM ORDER

This matter is before the court on defendant’s motion to vacate jury’s award of punitive damages and to enter judgment in favor of defendant, pursuant to Rule 59(e), Federal Rules of Civil Procedure. The issue presented is whether a jury can award punitive damages absent a finding of compensatory or nominal damages. For the reasons stated below, the court concludes that where the jurors’ intent is clear and the evidence supports their verdict, an award of punitive damages absent a predicate award of compensatory or nominal damages will stand undisturbed.

FACTS

Plaintiffs sued…