For a court to award punitive damages, a plaintiff must prove that defendants acted willfully, wantonly and maliciously. Good faith is a proper defense to punitive damages, even though defendants might have been mistaken in their belief that a party was in jeopardy or that their actions were correct.
Plaintiff daughte, while in college, had become a member of a cult. Her parents became concerned after her grades dropped and her personality changed. The parents took her to the house of a cult deprogrammer for "deprogramming" for a period of 16 days. Plaintiff initiated an action against defendants for false imprisonment and intentional infliction of emotional distress. The district court directed a verdict in favor of defendant former minister, exonerated defendant parents of the charge of false imprisonment, and found defendant cult deprogrammers liable for intentional infliction of emotional distress. On appeal, the court affirmed the judgment of the trial court.
Did the trial court err in admitting evidence to show that defendants acted in the good faith belief that plaintiff had been subjected to psychological duress by a religious group or sect?
In determining whether defendants acted with the requisite degree of malice, the trial court considered defendants' perceptions of The Way Ministry and their fears for Susan's well-being relevant and admissible. Since an award of punitive damages rests with the discretion of the jury, to have excluded all evidence bearing a potentially prejudicial impact would have eviscerated defendants' right to defend against the charge of intentional infliction of emotional distress. In an action for intentional infliction of emotional distress, when the record discloses no testimony impinging upon religious belief, the introduction by defendants of relevant evidence concerning matters that plaintiff voluntarily placed in issue, such as her religious association and defendants' state of mind, was admissible and did not violate the First Amendment admonition respecting freedom of religion.