United States Third Circuit

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In re Lemington Home for the Aged, 13-2707

In this case a jury found defendants, two former Officers and fourteen former Directors of a nursing home, liable for breach of fiduciary duties and deepening insolvency, and imposed punitive damages against some of those defendants. The jury's liability findings and punitive damages award imposed against the Administrator and Chief Financial Officer of the nursing home is affirmed, but the jury's award of punitive damages against those defendants who served on the nursing home's board of directors is vacated, where: 1) the punitive damages award against the board of directors defendants was not supported by evidence sufficient to establish that they acted with malice, vindictiveness, and a wholly wanton disregard of the rights of others; and 2) taken together with the other evidence of their malfeasance, the Administrator's and Chief Financial Officer's obfuscations at trial offered further support for the conclusion that they had acted outrageously, supporting the imposition of punitive damages against them.

Appellate Information

  • Decided 01/26/2015
  • Published 01/26/2015

Judges

  • Vanaskie

Court

  • United States Third Circuit

Counsel

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