Faulk v. Aware, Inc.
Supreme Court of New York, Appellate Division
244 N.Y.S.2d 259 (App. Div. 1963)
John Henry Faulk (plaintiff), a popular radio and television performer, sued Aware, Inc. and its president, Vincent Hartnett (defendants), for libel after they widely distributed statements accusing him of communist sympathies. Faulk presented expert testimony that his earning potential, absent the statements, ranged from $100,000 to $1,000,000 per year, and showed that his work opportunities collapsed after the statements were published. A jury awarded him $1,000,000 in compensatory damages and $1,250,000 in punitive damages against Aware and Hartnett combined, and the trial court upheld the award before Aware and Hartnett appealed.
Whether a jury's award of special damages in a defamation case must be reduced when it is excessive even though it has some rational basis.