Owens-Illinois, Inc. v. Zenobia
Court of Appeals of Maryland
601 A.2d 633 (1992)
Relevant factsFree
Asbestos plaintiffs (including Zenobia) sued Owens-Illinois (defendant), and the jury was instructed it could award punitive damages upon finding "implied malice," defined as gross negligence, ultimately finding for the plaintiffs and awarding punitive damages, a verdict an intermediate appellate court affirmed; Owens-Illinois appealed the punitive damages standard itself.
IssueFree
Whether Maryland law permits punitive damages based on a finding of implied malice (gross negligence) rather than requiring proof of actual malice.