Summary of Chuy v. Philadelphia Eagles Football Club, 595 F.2d 1265 3rd Cir (1979)
Plaintiff won seeking damages in breach of contract for (45k), (10k)f or compensatory damages, and (60,590) for Punitive Damages.= 115,590.96. Both parties have appealed. Chuy on defamation and Eagles on the *contract and *emotional distress claims. Appeal Affirmed.
Relevant Facts: The (p) Chuy sustained injuries while playing football for the Philadelphia Eagles. The Philadelphia Eagles’ doctor told him that he suffered from a pulmonary embolism and a blood clot in his lung, marking the end of his career. Soon the entire country was notified of Chuy’s disease. Chuy started to panic and decided to see his own doctor. (Dr. Perry was notified). The doctor told him the first physician’s diagnosis was false. Despite what his Doctor told him, he became very apprehensive and states he broke down emotionally and cannot cope with daily routines. He is also frightened by the prospect of imminent death and also developed marital difficulties. Chuy is now bringing suit against the Eagles for anti-trust violations, intentional infliction of emotional distress and defamation.
Legal Issue(s): Can the Eagles be held responsible for 1. (Intentional Infliction of emotional distress? (2) Punitive Damages (3) Defamation. Whether the doctors conduct was extreme and outrageous.
Holding– 1(Yes = 60,000) 2.(YES)= 6x the amount of compensatory. 3. (NO) could not prove that the doctor knew that he was going to harm Chuy. The jury had to prove reckless conduct and the instructions were adequate to establish recklessness, the statement made by the doctor had to know that it would with “substantial certainty" that he would intentionally harm Chuy. They had to be reasonable that the intended harm would occur. The main focus on the Holding is the fact of DIVERSITY JURISDICTION. The reporter was from the west coast and this provided problems for the courts.
Procedure: The Anti trust was dismissed. He lost the
Law or Rule(s):
Intent. Infliction of Emotional distress.- 4 elements to the action under §46 (1) the conduct must be extreme and outrageous (2) the conduct must be intentional or reckless (3) it must cause emotional distress (4) and the distress must be severe. The expression is measured by what a “reasonable" man could be expected to endure.
Punitive damages– could be awarded as a deterrent for others who might be likeminded. As defined by §908(1) of the est. Are damages other than compensatory or nominal “awarded against a person to punish him for outrageous conduct."
Defamation– A communication is defamatory if it tends so to harm the reputation of another as to lower him in the estimation of the community or to deter third persons from associating or dealing with him.
Defendants argument: the court gave improper instructions concerning the intent necessary for the tort and lacking insufficient evidence for the jury to find the required intent; that Chuy’s allegedly exaggerated and unreasonable reaction to Dr, Nixons remarks precludes the Eagles liability; and that the eagles cannot be vicariously liable even if Dr. Nixon’s intentionally or recklessly caused Chuy severe emotional distress.
***Eagles also contend that the district court erred in charging the jury on intent and recklessness.
***The Eagles assert that Chuy’s failure to secure prompt medical verification of his putative illness was unjustified, precluding liability for the infliction of emotional distress.