National By-Products, Inc. v. Searcy House Moving Co.
Arkansas Supreme Court
731 S.W.2d 194 (1987)
Robert Foley (defendant), driving an overloaded, 80,480-pound tractor-trailer for National By-Products (defendant) about 70 mph -- 15 mph over the limit -- crashed into a vehicle and Searcy House Moving Co.'s (plaintiff) house-in-transit after failing to slow down despite visible congestion ahead caused by Searcy adjusting its house load under a bridge; two people died in the crash, and it later emerged Foley's brakes were faulty, with National two-and-a-half months overdue on required brake maintenance, though Foley himself had diligently performed his own routine brake inspections and had no knowledge of the defect. A jury awarded compensatory and punitive damages against National and Foley, including $100,000 in punitive damages to Searcy, and National appealed the punitive award.
Whether an award of punitive damages is appropriate where the defendant did not proceed intentionally after knowing that the act would naturally and likely lead to injury.