Gryc v. Dayton-Hudson Corp (Dept store) Case Brief

Summary of Gryc v. Dayton-Hudson Corp (Dept store), S. Ct MN [1980]

Punitive Damages

Relevant Facts: Pl’s 4y/o daughter was clothed in pajamas made from cotton material manufactured by Df Riegel. The material was commercially known as flannelette. It was not treated but did meet the Fed. min. standards of product flammability. Pl daughter reached across an electric stove when her pajamas were instantly ignited and she received severe burns across her upper body. Evidence was entered that the fabric was defective. Pl were awarded $750,000 compensatory damages and $1,000,000 punitive damages.

Legal Issue(s): 1-Whether the trial court applied the proper legal standard in instructing the jury on the issue of punitive damages; 2-Whether there was sufficient evidence to support the award of punitive damages in this case; 3- Whether the award of $1,000,000 in punitive damages is excessive?

Court’s Holding: Yes, Yes, and No.

Procedure: D Ct entered judgment on jury verdict, Df appealed; S C Affirmed.

Law or Rule(s): When a party is found to have acted either maliciously or in a wilful or wanton manner, you may award exemplary or punitive damages.

Court Rationale: Where appellant failed to object below to instruction by trial court on issue of punitive damages, instruction became law of case and was not subject to review on appeal. After taking into consideration the factors, there is substantial evidence for the jury to have found that the Df acted in willful, wanton, and malicious disregard of the rights of others in marketing it flannelette. Df has been shown to have acted in reckless disregard of the public for purely economic reasons in the past. Punitive damages severs to deter Df from acting in a similar manner with respect to other products manufactured by it in the future. Since the potential of compensatory damages awards and loss of sales and reputation did not serve to deter Df in the past, Df cannot now argue that these considerations act as an adequate deterrent. One of the functions of punitive damages award is to punish past misconduct. This ct will not disturb a punitive damages award UNLESS it appears that the award was actuated by passion and prejudice and is so excessive as to be deemed unreasonable. Here it is not unreasonable.

Plaintiff’s Argument: Df continued to market a product containing a highly flammable cotton flannelette when it was aware of the danger and made substantial profits through the sale of the product.

Defendant’s Argument: The award was clearly excessive and unreasonable. The compensatory damages and loss of sales and reputation act as adequate deterrents.

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