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Keywords

tortdamagestrialverdictmotionpunitive damagescompensatory damagesappellantappellee
damagestrialpunitive damagescompensatory damagesappellantappellee

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Bell v. McManus, 294 Ark. 275, 742 S.W.2d 559

Facts

The appellants, Darlene and Melvyn Bell, alleged that the appellee masterminded the burglary of their home, resulting in the theft of $7,400 worth of personal property. During the trial, Mrs. Bell testified about the emotional distress they experienced due to the violation of their home. However, the jury found no compensatory damages were suffered, only awarding punitive damages to Mrs. Bell. The trial court later dismissed Mr. Bell's cause of action due to his absence at trial.

The appellants filed a complaint in the circuit court which alleged that appellee masterminded the burglary of their home by two teenagers who stole $7,400 worth of their personal property.

Issue

Did the trial court err in ruling that punitive damages cannot be awarded in the absence of compensatory damages, and was there sufficient evidence to support the jury's finding of no compensatory damages?

Did the trial court err in ruling that punitive damages cannot be awarded in the absence of compensatory damages, and was there sufficient evidence to support the jury's finding of no compensatory damages?

Rule

The court held that punitive damages cannot be awarded without an underlying award of compensatory damages, even if compensatory damages were suffered. The tort of outrage requires proof of extreme and outrageous conduct that causes severe emotional distress.

In the absence of an award for damages for the underlying cause of action, punitive damages are improper.

Analysis

The court applied the rule by examining the jury's verdict, which found that Mrs. Bell suffered no compensatory damages. Since punitive damages are contingent upon the existence of compensatory damages, the court concluded that the jury's finding was proper and that the trial court correctly granted the judgment notwithstanding the verdict.

The jury simply found that Mrs. Bell had not suffered compensatory damages. In the absence of an award for damages for the underlying cause of action, punitive damages are improper.

Conclusion

The Supreme Court affirmed the trial court's decision, holding that the absence of compensatory damages barred the recovery of punitive damages.

Affirmed.

Who won?

The appellee prevailed in the case because the court found that the jury's determination of no compensatory damages was supported by the evidence, thus precluding any punitive damages.

The appellee prevailed in the case because the court found that the jury's determination of no compensatory damages was supported by the evidence.

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