Federal Court Requires Pleading of Sufficient Facts to Support Claims of Punitive Damages

In the case of McKinney v. GM, LLC, No. 1:24-CV-00140-SPB (W.D. Pa. Aug. 28, 2025 Baxter, J.), the Western District Federal Court granted a partial Motion to Dismiss claims of punitive damages.

The court granted the Motion after finding that the Plaintiff failed to plead sufficient facts to support a punitive damages claim.

The court noted that recklessness that could support a punitive damages claim must involve more than claims of ordinary negligence. Rather, the conduct involved must be intentional and the risk substantially greater than that which is necessary for conduct to be negligent.

Here, the court found that the product liability Complaint contained no factual allegations identifying the nature of the alleged defect, how the Defendant alleged became aware of it, or what actions the Defendant failed to take in conscious disregard of that risk.

The court emphasized that punitive damages are to be considered an extreme remedy that are not available for conduct arising from mere inadvertence, mistake, or errors in judgment.

The court also noted that the Complaint failed to contain any factual allegations that even suggested that the Defendant acted with an evil motive or in conscious disregard of a known risk.

Anyone wishing to review a copy of this decision may click this LINK.

I send thanks to Attorney James M. Beck of the Philadelphia office of the Reed Smith law firm for bringing this case to my attention.