Janet Carmichael and Carmichael’s Homgas Plumbing & Heating, Inc. v. Adirondack Bottled Gas Corporation of Vermont

Summary

The court affirmed a jury verdict awarding Janet Carmichael compensatory and punitive damages for Adirondack's breach of the implied covenant of good faith and fair dealing in terminating their business relationship. It held that the covenant continued to govern the parties' post-termination dealings, that the evidence supported the verdict, and that Carmichael's claim was not precluded by the arbitration award or federal antitrust dismissal. The court also upheld the rulings on waiver of objections to punitive-damages instructions, accord and satisfaction, and prejudgment interest.