New York Court of Appeals
Richard D. W. Kiff, Respondent v. William Youmans, Appellant
October 11, 188186 N.Y. 324
Summary
The Court of Appeals reversed the judgment and ordered a new trial because the trial judge erred in allowing the jury to consider punitive damages when the plaintiff was a trespasser and the defendant used only necessary force. The Court held that punitive damages are unavailable in such circumstances and that the plaintiff's own fault mitigates any compensatory recovery.