Peete v. Blackwell
Alabama Supreme Court
504 So.2d 222 (1986)
While treating a patient at risk of suffocating from a failed nasal pack, Dr. Robert Peete (defendant), who had a documented history of yelling, cursing, and throwing objects at hospital staff, struck nurse Beverly Blackwell (plaintiff) on the forearm and cursed at her while demanding she operate suction equipment during the emergency procedure; Blackwell sued for assault and battery, testifying she suffered no physical injury from the strike, though evidence showed Peete had slammed a patient chart moments before the incident. A jury awarded Blackwell $1 in compensatory damages and $10,000 in punitive damages, and after the trial court denied Peete's motions for a new trial and judgment notwithstanding the verdict, he appealed.
Whether sufficient evidence supported a punitive damages award for assault and battery where the defendant's strike caused no physical injury but was accompanied by cursing and a history of aggressive conduct toward staff, occurring during a genuine medical emergency.