Egan v. Butler
Annotate this CaseAfter Plaintiff was fired, his former supervisor swore out a misdemeanor assault and battery complaint against Plaintiff for events that allegedly occurred immediately after Plaintiff’s termination. The supervisor also told other employees at Plaintiff’s former workplace that Plaintiff had cut or stabbed him. The misdemeanor assault and battery charge was later dismissed. Plaintiff filed a complaint against his former supervisor and his former employer (collectively, Defendants) alleging malicious prosecution and defamation. The jury returned a verdict in favor of Plaintiff. Plaintiff was awarded both compensatory and punitive damages. The Supreme Court affirmed, holding (1) the trial court erred when it excluded evidence of Plaintiff’s work history and quality of past job performance, as the excluded evidence was probative of future lost income, and the error was not harmless; and (2) the evidence introduced at trial was insufficient to subject Plaintiff’s former employer to punitive damages liability. Remanded.
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