Missouri Court of Appeals, Southern District / Apr 11, 2023
VIVIAN BADILLO, Appellant vs. THE HOME CITY ICE COMPANY, and MYLES MATHIS, Respondents
Vivian Badillo was injured in an auto accident caused by Myles Mathis, an employee of The Home City Ice Company. Badillo sued Mathis for negligence and Home City Ice for negligence based on respondeat superior, seeking punitive damages against both. The trial court excluded evidence related to Home City Ice's hiring, training, and policies, finding it irrelevant to a punitive damages claim based solely on vicarious liability. The jury awarded compensatory damages but denied punitive damages. The appellate court affirmed, holding that the trial court did not abuse its discretion in excluding the evidence because it was not relevant to a punitive damages claim based only on vicarious liability.