Sunkist Enterprises v. Mahmood
Irfan Mahmood sought to recover damages for defamatory statements made about him by his uncle Syed Ali Husain. After a liability phase trial, the jury found that Husain had defamed Mahmood, that Husain acted with malice, oppression, or fraud when he defamed Mahmood, and that Mahmood was entitled to $60,000 in nominal damages. A second jury found that Mahmood was entitled to $1 million in punitive damages. On August 12, 2008, the trial court entered judgment on the jury's verdicts. Thereafter, the trial court denied Husain's motions to vacate the judgment and for judgment notwithstanding the verdict. Husain's motion for a new trial was denied after Mahmood consented to a remittitur in damages to $45,000 in compensatory damages and $450,000 in punitive damages. On October 20, 2008, the trial court entered an amended judgment reflecting the remitted damage awards. Husain appeals from the judgment and the denial of his post trial motions to the extent they are adverse to him and both Husain and Mahmood appeal from the amended judgment. Husain presents various arguments seeking, among other things, reversal of the amended judgment, or alternatively, a reduction of the award of punitive damages on the ground that the remitted award is unconstitutionally excessive. Mahmood cross-appeals seeking reinstatement of the jury's award of punitive damages in the sum of $1 million.[1] We affirm.[2]
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