Boise Dodge, Inc. v. Clark

Clark (the defendant) bought a car from Boise Dodge, Inc. (the plaintiff). The odometer on the car showed 165 miles and was described by the plaintiff’s salesman as “new.” However, the car was actually a demonstrator, and the plaintiff’s general manager knew the odometer was set back from 7,000 miles. The defendant traded an old car worth $1,100, issued a $500 check, and paid $1,562 in cash for the car. Later, the defendant discovered the car was actually used and stopped payment on his checks. The plaintiff sued to recover the value of the stopped checks. The defendant counterclaimed for damages for breach of contract and fraud, and sought punitive damages. The case was tried before a jury. The jury was instructed that it could award punitive damages to the defendant, but that the award of punitive damages must bear a “reasonable relation” to any actual damages suffered. Subsequently, the jury awarded $2,062 in damages to the plaintiff and awarded $350 (the difference between the value of the car as represented by the plaintiff) and $2,050 (the actual value of the car) to the defendant. In addition, the jury awarded the defendant $12,500 in punitive damages. The appellate court affirmed the award of punitive damages, and the plaintiff appealed.