Egan v. Butler, 772 S.E.2d 765
Jun 04, 2015OUTCOME: Reversed and remanded in part, and final judgment in part.
HOLDINGS: [1]-Where a former employee sued his former supervisor and employer for malicious prosecution and defamation, the trial court erred in excluding evidence of his past employment history and th ... e quality of his job performance, as it was probative of the future lost income damages he claimed; the error was not harmless, as the excluded evidence would have made the award less speculative; [2]-The trial court erred in denying the employer's motion to strike the punitive damages claims asserted against it, as there was no evidence it engaged in, authorized, or ratified the supervisor's actions, and the evidence did not establish that the supervisor was in a sufficiently high position so that his actions were actually the employer's actions for purposes of punitive damages liability.