Whitaker Farms, LLC v. Fitzgerald Fruit Farms, LLC

Summary

The court held that statements made during settlement negotiations were inadmissible when offered to establish liability for punitive damages. Although the statements were characterized as evidence of the defendant’s state of mind, that state of mind was an element of the punitive-damages claim, so the evidence was offered for a purpose prohibited by Rule 408. The court vacated the judgment and remanded for consideration of whether the error was harmful and requires a new punitive-damages trial.