Federal Court Rules on Propriety of Financial Wealth Discovery in Punitive Damages Cases

In the case of N’Jai v. Bentz, Civil Action No. 13-1212 (W.D. Pa. Nov. 24, 2015 Fischer, J.), the court denied a Plaintiff’s Motion to Compel relative to a punitive damages claim.

In so ruling, the federal court asserted that a Plaintiff is not automatically entitled to discovery of a Defendant’s financial wealth simply by successful pleading a punitive damages claim.  Rather, the court noted that a Plaintiff must go beyond the pleadings and produce prima facie evidence to show a right to recover punitive damages before a court would permit such financial wealth discovery.  

Stated otherwise, the court found that financial wealth discovery is not appropriate in a civil litigation matter until there is a reasonable evidentiary basis to show that a Plaintiff’s punitive damages claims can be submitted a jury.  

Anyone wishing to review this case online may click this LINK.

 

I thank Attorney James M. Beck of the Philadelphia office of Reid Smith for bringing this case to my attention.