Smith's Food & Drug Centers, Inc. v. Bellegarde

OPINION

This is an appeal from an order denying appellant’s motion for judgment notwithstanding jury verdict or, in the alternative, for new trial. The primary claim of error is addressed to the district court’s refusal to strike an award of punitive damages against a corporate defendant where the jury failed to impose punitive liability on corporate employees. We affirm.

FACTS

On October 19, 1989, respondent Argentine Bellegarde (“Bellegarde”), a twenty-four year old Haitian immigrant, was accused of shoplifting by employees of a Smith’s Food & Drug Center (“Smith’s”) in Las Vegas. The store in…