Lompe v. Sunridge Partners LLC, No. 14-8082 (10th Cir. 2016)Annotate this Case
Plaintiff-appellee Amber Lompe was exposed to high levels of carbon monoxide (CO) from a malfunctioning furnace in her apartment at the Sunridge Apartments in Casper, Wyoming. Plaintiff brought a diversity action in the Federal District Court for the District of Wyoming against Sunridge Partners LLC (Sunridge) and Apartment Management Consultants, L.L.C. (AMC), the owner and the property manager. The jury found both Defendants liable for negligence and awarded plaintiff compensatory damages totaling $3,000,000 and punitive damages totaling $25,500,000, of which the jury apportioned $3,000,000 against Sunridge and $22,500,000 against AMC. Defendants challenged the jury’s award of punitive damages, arguing the district court erred in failing to grant their motion for judgment as a matter of law (JMOL) as to punitive damages. Alternatively, they contended the district court’s jury instructions on punitive damages were erroneous and the amount of punitive damages awarded against each Defendant was excessive under common law and constitutional standards. After review, the Tenth Circuit held that the evidence was insufficient to submit the question of punitive damages to the jury as to Sunridge, and the amount of punitive damages awarded against AMC was grossly excessive and arbitrary in violation of the Due Process Clause of the Fourteenth Amendment. Accordingly, the Court vacated the award of punitive damages against Sunridge and reduce the punitive damages awarded against AMC from $22,500,000 to $1,950,000.