Lyman v. CellChem International, Inc.Annotate this Case
After Dale Lyman and his wife, Helen, left Cellchem International, Inc. to work for a competitor, Cellchem sued the Lymans and two companies with which they had affiliated (collectively the “Lymans”), asserting claims for computer theft and computer trespass under the Georgia Computer Systems Protection Act(GCSPA, breach of fiduciary duty, and tortious interference with business relations. Cellchem claimed that the Lymans stole data from Cellchem and used it to their competitive advantage. At trial, the jury found the Lymans liable on all claims and awarded Cellchem compensatory damages and attorney fees, as well as punitive damages of $5.1 million. On appeal, the Court of Appeals reversed the judgment against the Lymans on the tortious interference claim. The Court of Appeals also remanded the case to the trial court for a new trial as to punitive damages, reasoning that, despite the fact that the tortious interference claim no longer existed to support a potential award for punitive damages, the remaining claims for breach of fiduciary duty and violations of the GCSPA could still support such a claim. In this regard, because the verdict form at trial did not designate to which claims the punitive damages were assigned, or in what proportion, a new determination had to be made with regard to punitive damages that eliminated any consideration of damages associated with alleged tortious interference and focused only on the remaining tort claims upon which the Lymans had been found liable at trial. After its review of the matter, the Supreme Court concluded that the GCSPA did not authorize an award of punitive damages. Accordingly, the Court reversed the Court of Appeals with respect to the availability of punitive damages under the GCSPA, and remanded this case with directions that the appellate court clarify that any remand to the trial court for a new trial on the issue of punitive damages could not involve any purported award for such damages based on alleged violations of the GCSPA.