Peisner v. Detroit Free Press, Inc.

We granted leave in this case to consider whether an award of "exemplary and punitive” damages under Michigan’s libel statute impermissibly duplicates an award of actual damages for injury to feelings arising from the libel. In addressing that question, we reaffirm that "exemplary and punitive” damages under the libel statute are purely compensatory in nature, but hold that their availability requires a showing of common-law malice. We further hold that, under proper instruction, a jury may award exemplary and punitive damages that are not duplicative of actual damages for injury to feelings.…