Waste Mgmt. of Tex., Inc. v. Tex. Disposal Sys. Landfill, Inc. (Opinion)
Annotate this CaseWaste Management of Texas, Inc. (“WMT”) and Texas Disposal Systems Landfill, Inc. (“TDS”) competed for waste-disposal and landfill-services contracts with two Texas cities. During the bidding process, WMT anonymously published a community “Action Alert” claiming that TDS’s landfills were less environmentally sensitive than they actually were and as compared to other area landfills. TDS sued WMT for defamation. After a second trial, the jury returned a verdict in favor of TDS, awarding it $450,592 for expenses, $5 million for injury to reputation, and $20 million as exemplary damages. The trial court treated the $5 million award for injury to reputation as non-economic damages for purposes of the statutory cap on exemplary damages and rendered an exemplary damage award of approximately $1.6 million. Both parties appealed. The Supreme Court affirmed in part and reversed in part, holding (1) a corporation may suffer reputation damages, and such damages are non-economic in nature for purposes of the statutory cap on exemplary damages; (2) the evidence in this case was not sufficient to support the award of reputation damages; and (3) TDS was entitled to exemplary damages, but the amount must be recalculated.
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