King v. U.S. Bank National Assn.Annotate this Case
A jury returned verdicts in favor of plaintiff Timothy King against defendant U.S. Bank National Association (U.S. Bank) for defamation, wrongful termination in violation of public policy, and breach of the implied covenant of good faith and fair dealing, awarding King almost $24.3 million in compensatory and punitive damages. King started in the position of senior vice president regional manager, market lead, and market president for U.S. Bank’s Sacramento area in January 2007. In 2012, two of King's subordinates contacted the Bank's human resources department, raising claims of gender discrimination and harassment. There was substantial evidence from which the jury found the subordinates were biased and hostile toward King, and thus there were "obvious reasons to doubt the veracity of the informant[s] or the accuracy of his [and her] reports." U.S. Bank moved for judgment notwithstanding the verdict on the ground that there was no substantial evidence to support the jury’s verdicts and the award of punitive damages. The trial court denied the motion. U.S. Bank also moved for new trial on the grounds that there was insufficient evidence to support the verdicts, the damages were excessive, and there was an irregularity in the proceedings that prevented a fair trial. The trial court conditionally granted the motion for new trial on the excessive damages ground conditioned upon King agreeing to a remittitur, but denied the motion on the other grounds asserted. King accepted the remittitur and the trial court entered judgment on the remitted award of over $5.4 million. U.S. Bank appeals, challenging the jury’s verdicts on each of the causes of action and the remitted award of punitive damages. King cross-appealed, challenging the trial court’s new trial orders on excessive damages. The Court of Appeal reversed the trial court’s new trial orders, but agreed with the trial court, following its own independent review, that a one-to-one ratio between compensatory and punitive damages was the constitutional limit under the facts of this case. The Court remanded with directions to modify the judgment accordingly.