The Missouri Supreme Court ruled in favor of imposing limitations on a $5.5 million punitive jury trial damages award.
In All-Star Awards & Ad Specialties Inc. v. Halo Branded Solutions Inc., plaintiff All-Star appealed the post-trial application of Section 510.265, which not only lowered $5.5 million in damages to $2.5 million but also allegedly violated their rights to a jury trial.
As previously reported in St. Louis Record, 510.265 RSMo limits an award of punitive damages to $500,000 or five times the net amount of the judgment awarded to the plaintiff against the defendant.
“I was actually somewhat surprised by the Western District Appellate Court’s reversal of the trial court decision,” said David Eisenberg, an attorney with Baker Sterchi Cowden & Rice and editor of the firm's Missouri Law Blog. “I thought it was likely that the Supreme Court would take the course that it did.”
The Missouri Supreme Court voted 6-1 to uphold the decision of the Jackson County Circuit Court, which ruled in favor of capping damages.
“When the Missouri Supreme Court accepts a case, it completely sets aside the Court of Appeals decision and reviews de novo what the trial court did,” Eisenberg told the St. Louis Record.
The Supreme Court's decision prevents All-Star from collecting the larger amount of punitive damages unreduced by the damages cap.
“I don't think there is really anything left for the courts to do other than just the administrative step of the trial court entering a final judgment against Halo Branded Solutions for the actual damages and for punitive damages in the reduced amount and that will be it,” Eisenberg said.
While Judge George W. Draper III dissented without issuing an opinion, Judge W. Brent Powell, affirmed the Jackson County Circuit Court judgment stating that the trial court did not err in reducing the plaintiff’s punitive damages award because its common law causes of action either did not exist prior to 1820 or are not analogous to claims existing before 1820 for which juries could have awarded punitive damages.
“If a case has been brought under a common law cause of action, and a good example might be fraud, and that same cause of action existed at the time the Missouri state constitution was enacted in 1820 and that cause allowed a trial by jury and punitive damages at the time, then the application of a statutory limit on punitive damages would abridge the right to a jury trial,” Eisenberg added. “That's the rule.”