Lindsey v. Miami County National Bank

The opinion of the court was delivered by

Larson, J.:

Michael Lindsey appeals the trial court’s denial of his claim for punitive damages in his suit against the Miami County National Bank (Bank) for conversion after a Bank employee wrongfully took Lindsey’s car, believing it to be one in which the Bank had a security interest.

Lindsey was awarded actual damages of $5,500 after a jury trial and now contends (1) a prima facie case is made for punitive damages when a secured creditor, while exercising a self-help repossession, takes property it has no security interest in, (2) the Bank is…