Williams v. First Advantage Background Services Corp., No. 17-11447 (11th Cir. 2020)
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Defendant appealed the district court's denial of its motion for judgment as a matter of law, or in the alternative, motion for a new trial or remittitur. In this Fair Credit Reporting Act (FCRA), the Eleventh Circuit affirmed the district court's denial of defendant's motion for judgment as a matter of law to the extent it challenged the reputational harm claim and the willfulness claim.
However, the court vacated the jury's punitive damages award and remanded the case to the district court to enter a judgment awarding plaintiff $1 million in punitive damages. The court held that, although punitive damages were properly awarded, a $3.3 million dollar award was unconstitutionally excessive.
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