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. A request for punitive damages is a claim under Rule 408, and evidence of a party's state of mind offered to prove an element of that claim is evidence offered to prove liability for the claim. The court vacated the Court of Appeals' judgment and remanded for a harmless-error determination concerning whether the admission of the statements required a new punitive-damages trial.