Jacque v. Steenberg Homes, Inc.
Facts:
Steenberg Homes wanted to deliver a home across Jacque's snow-covered field because it was much easier than the alternative route. Despite his direct refusal, Steenberg plowed a path and delivered the home across the path.
Procedural History:
The trial jury awarded $1 in nominal damages and $100,000 in punitive damages. The circuit court reversed the $100,000 punitive damages award.
Issues:
Can an award of nominal damages for intentional trespass to land support a punitive damage award?
Should the law apply to Steenberg or only prospectively?
Is the $100,000 punitive damage award excessive?
Plaintiff's Argument:
Punitive damages should be allowed with only nominal damages when the act is a trespass to land.
Defendant's Argument:
Punitive damages could not be awarded by the jury because punitive damages have to be supported by compensatory damages, while the jury only awarded nominal and punitive damages here.
Rule:
Nominal damages are enough for punitive damages whenever the tort in question is a trespass to land.
Reasoning:
This was a trespass to land, so punitive damages are allowed for a trespass to land. The cost to the trespasser must outweigh their benefit in order to stop them from doing it in the future, so such a value is allowed for the public interest.
Holding:
Yes, such an award is appropriate here and $100,000 is an appropriate amount. Original damages restored.
Takeaway:
When nominal damages are given in a trespass to land, punitive damages may also be given.