Franchise Tax Board v. HyattAnnotate this Case
The Constitution does not permit Nevada to award damages against California agencies under Nevada law that are greater than it could award against Nevada agencies in similar circumstances. Therefore, the Nevada Supreme Court's special rule of law that FTB was not entitled to a damages cap that a Nevada agency would be entitled to violated the Constitution's requirement that full faith and credit shall be given in each state. On remand from the United States Supreme Court, the Supreme Court of Nevada reissued its vacated opinion except as to the damages portions addressed by the Supreme Court and applied the statutory damages caps FTB was entitled to under Hyatt II. The state supreme court concluded that sufficient evidence supported a damages award up to NRS 41.035(1)'s $50,000 statutory cap and thus the district court should have awarded plaintiff damages in that amount for his intentional infliction of emotional distress claims; plaintiff was not entitled to prejudgment interest on these damages awards; plaintiff was precluded from recovering punitive damages against FTB; costs awards were reversed and remanded for a new determination; and the district court's prior summary judgment as to plaintiff's claim for economic damages on plaintiff's cross-appeal affirmed.