Graham v. Brown
Annotate this CaseSarah Graham filed a complaint against Shyam Brown, alleging physical, emotional, and mental abuse, and seeking damages. Brown did not file an answer, and the district court entered a default against him. After a hearing on damages, the court awarded Graham compensatory damages of $50,000 and punitive damages of $5,000. On appeal, the Supreme Court affirmed, holding (1) the district court did not abuse its discretion by declining to set aside the entry of default; (2) the district court did not err by holding that Brown was liable for intentional infliction of emotional distress and entering a default judgment accordingly; and (3) the district court did not err in its determination of compensatory damages, and the punitive damages award was not excessive.
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