Court of Appeals Holds that Admission of Liability Does Not Preclude Evidence of How an Incident Occurred If Relevant to the Issue of Punitive Damages
On September 19, 2019, the Court of Appeals decided Edwards v. Safeway, Inc., 17-CV-464, Slip. op. (D.C. Sept. 19, 2019) in which it considered, inter alia, whether the plaintiff in the proceedings below was entitled to present evidence of punitive damages for the defendant’s conversion of her personal property.
The trial court “precluded [the plaintiff] from presenting evidence of punitive damages . . . based both on its understanding” that the manner in which the defendant converted the property did not matter, and because the defendant “had admitted liability.” Slip op. at 6-7. The plaintiff obtained a jury award of compensatory damages for conversion and then appealed the trial court’s decision with respect to punitive damages. Id. at 2-4.
The Court of Appeals ruled that the trial court’s decision to preclude the plaintiff from presenting evidence of punitive damages was wrong. Id. at 6-9. First, it held that the manner in which the defendant converted the plaintiff’s property “did matter” because “[p]unitive damages may properly be awarded in an action for conversion where the act of the defendant is accompanied with fraud, ill will, recklessness, wantonness, oppressiveness, willful disregard of the plaintiff’s rights, or other circumstances tending to aggravate the injury.” Id. at 7 (internal quotation marks omitted).
Second, the Court of Appeals held that the defendant’s “admission of liability was immaterial, because a plaintiff’s entitlement to punitive damages” is separate from the issue of whether the defendant is liable. Id. at 8. It noted that “a number of courts have previously concluded, and we now likewise hold, that [an admission of liability] does not preclude a plaintiff from showing how the incident happened if such evidence is material and relevant to the question of punitive damages.” Id. at 8 (internal quotation marks, brackets, and ellipse omitted).
Accordingly, the Court of Appeals reversed the trial court’s decision with respect to punitive damages and remanded for further proceedings. Id. at 9.