Defamation Plaintiff’s Punitive Damages Verdict Reviewed By Manifest-Weight-Of-The Evidence

Wallace Leyshon was fired from his job for cause by Diehl Controls North America. Leyshon sued Diehl for, among other things, defamation. A jury awarded Leyshon $2 million in compensatory damages and $10 million in punitive damages. Diehl asked the trial court to lower the punitive damages verdict, which it did, to $6 million.

Still unhappy, Diehl appealed. One of Diehl’s positions on appeal was that the punitive damages award was excessive. The question was whether Leyshon had sufficient facts at trial to support the punitive damages verdict. The First District Illinois Appellate Court first considered the standard of review: “As the jury’s determination of the amount of punitive damages is predominately a factual issue, the [appellate] court will not reverse the award unless it is against the manifest weight of the evidence.”

In this case, there was evidence that Diehl’s actions were premeditated. So the appellate court affirmed the punitive damages award. Read the whole case, Leyshon v. Diehl Controls North America, No. 1-09-1848 (12/27/10).

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