(Please note: the names and locations of all parties have been changed to protect the confidentiality of this personal injury case and its proceedings.)
3. Other cases
Holdgrafer is far from the only post-State Farm appellate decision vacating a punitive award after holding that other acts evidence was improperly admitted. Courts around the country have repeatedly done the same:
The Arkansas Supreme Court ordered a new trial on punitive damages in a case brought against a chemical manufacturer by farmers whose wheat crops were rendered unfit for sale when they were sprayed with an insecticide that was later determined to be unsafe for use on wheat. The plaintiffs had introduced evidence that the defendant had recommended the product for use not only on plaintiffs’ farms, but also on various other farms in Mississippi. The Court held that this evidence should not have been admitted, because it improperly invited the jury to impose punishment for conduct that harmed farmers other than the plaintiff. See FMC Corp. v. Helton, 360 Ark. 465 (2005).
The Indiana Court of Appeals vacated a punitive award in a negligence suit brought against a drunk driver because the trial court had allowed the jury to hear evidence of the defendant’s other DUI arrests. That court recognized that evidence of the defendant’s similar acts might, in rare situation[s], assist the jury in determining the level of punitive damages necessary to deter future transgressions. But, citing State Farm, the court held that any relevance which [the defendant’s] subsequent acts could have had upon the issue of punitive damages was substantially outweighed by the danger that the jury would use this evidence to punish [him] for his subsequent acts instead of the conduct that gave rise to [the plaintiffs] actual damages. Wohlwend v. Edwards, 796 N.E. 2d 781,785, 787 (Ind. Ct. App. 2003).
The South Carolina Supreme Court vacated a punitive award in a medical malpractice case because the trial court admitted evidence that the doctor had not only given substandard treatment to the plaintiff, but had also improperly prescribed narcotics to the plaintiff’s daughter. The connection between this evidence and the conduct that harmed the plaintiff was attenuated, the court held, and the potential for prejudice outweighed the probative value. Durham v. Vinson, 360 S.C. 639 (2004). (See Part 6 of 7.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.