Heagney v. Wong, No. 17-2033 (1st Cir. 2019)Annotate this Case
The First Circuit affirmed in part and reversed in part the decision of the district court entering judgment for Plaintiff on Mass. Gen. Laws ch. 151B and defamation claims against the City of Fitchburg and its mayor and the award of punitive damages, holding that the award of punitive damages was improper and that the district court erred in entering judgment for Plaintiff on the defamation claim.
Plaintiff brought this action against the City and its mayor after the mayor decided not to nominate Plaintiff for the position of the City police chief. Plaintiff alleged that the City violated his rights under Chapter 151B by deciding not to hire him because of his failure to disclose a criminal case against him of which he was later acquitted and that the mayor defamed him through statements she made to the media. A jury found for Plaintiff on both claims and awarded punitive damages. The First Circuit held (1) the district court erred in denying Plaintiff’s motion for judgment as a matter of law and for a new trial on Plaintiff’s defamation claim because the statement at issue was not false; (2) the evidence was sufficient with respect to the Chapter 151B claim; and (3) there was insufficient evidence to support the punitive damages award.