Legal Memorandum: Court's Decision in Hadley v. VAM P.T.S.

Issue: What is the meaning of the Fifth Circuit’s decision in Hadley v. VAM P.T.S.?

Area of Law: Litigation & Procedure
Keywords: Punitive damages; Intentional infliction of emotional distress claim; No actual damage
Jurisdiction: Texas
Cited Cases: 44 F.3d 372; 846 S.W.2d 282
Cited Statutes: None
Date: 08/01/2001

In Hadley v. VAM P.T.S., 44 F.3d 372 (5th Cir. Feb. 15, 1995), the jury had specifically awarded punitive damages for intentional infliction of emotional distress but was not asked whether the plaintiff had suffered any actual damages as a result of that intentional infliction.  The court’s main concern in that regard was whether punitive damages could be awarded for an act for which no actual damages were awarded; based on clear Texas precedent, the court concluded that they could not.

See also Federal Express v. Dutschman, 846 S.W.2d 282 (Tex. 1993) (no actual damage question was submitted to the jury concerning the tort of violation of the covenant of good faith and fair dealing).


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