Supreme Court of Vermont
Ronald Lent v. H. J. Huntoon and Huntoon Business MacHines, Inc.
November 1, 1983143 Vt. 539
Summary
The Court affirmed a defamation judgment awarding the plaintiff $15,000 in compensatory damages and $25,000 in punitive damages. It held that even defamation actionable per se requires proof of actual harm for compensatory damages, and that the evidence supported findings of malice sufficient for punitive damages. The Court also concluded that defendants preserved only the punitive-damages issue for judgment notwithstanding the verdict and failed to show an abuse of discretion concerning the new-trial or remittitur rulings.