Section 84 Corporate Defendants

• Library: Damages 2012

Missouri does not follow the “complicity rule,” which holds that a corporate defendant is liable for punitive damages only when superior officers either order, participate in, or ratify outrageous conduct. See:

Tietjens v. Gen. Motors Corp., 418 S.W.2d 75, 88 (Mo. 1967)

Rinker v. Ford Motor Co., 567 S.W.2d 655, 669 (Mo. App. W.D. 1978)

Collins v. Adams Dairy Co., 661 S.W.2d 603, 606 (Mo. App. E.D. 1983)

Instead, action of a nature that gives rise to this liability by a corporate agent acting within the scope of the agent’s authority is all that is required to impose liability for punitive damages on a corporate employer. Tie...