Law School Case Brief
Yeakley v. Doss - 370 Ark. 122, 257 S.W.3d 895 (2007)
An award of punitive damages is justified only where the evidence indicates that the defendant acted wantonly in causing the injury or with such a conscious indifference to the consequences that malice may be inferred. In other words, in order to superadd this element of damages by way of punishment, it must appear that the negligent party knew, or had reason to believe, that his act of negligence was about to inflict injury, and that he continued in his course with a conscious indifference to the consequences, from which malice may be inferred. In order to warrant a submission of the question of punitive damages, there must be an element of willfulness or such reckless conduct on the part of the defendant as is equivalent thereto.
Plaintiff Ruby J. Yeakley was driving in a car with her two minor children, N.Y. and Z.Y., when their car was struck by vehicle driven by defendant Robert E. Doss. Yeakley, individually and as mother and next friend of N.Y. and Z.Y, subsequently filed a negligence action in Arkansas state court against Doss, seeking to recover damages for injuries they sustained in the accident. At trial, Yeakley sought to introduce evidence of Doss' prior convictions for driving while intoxicated (DWI). Doss filed a motion in limine to bar the admission of that evidence. The trial court granted the motion. The jury returned a verdict awarding Yeakley and N.Y. $ 5,000 each and Z.Y. $ 1,000 in compensatory damages. The jury also determined that punitive damages were not warranted. Yeakley appealed.
Did the court err in granting Doss' motion in limine?
The state supreme court reversed the trial court's judgment and remanded the mater. The court determined that the trial court erred by finding that the evidence of Doss' prior DWI convictions was not relevant under Ark. R. Evid. 401. Rather, it was relevant to the allegation that Doss acted with the knowledge that his conduct of driving while intoxicated could have resulted in injury and that he continued that conduct in reckless disregard of the consequence from which malice could have been inferred. The court held that the prior convictions had a tendency to make a fact that was of consequence to the determination of the action more or less probable. Evidence that Doss was intoxicated in one instance versus evidence that this was his third conviction for DWI could have impacted the jury's ability to award punitive damages.
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