Jacque v. Steenberg Homes, Inc.

Facts

Harvey and Lois Jacque owned roughly 170 acres in the town of Schleswig. In the fall of 1993, a neighbor bought a mobile home from Steenberg Homes, Inc., with delivery included in the price. Steenberg preferred crossing the Jacques' farm field because the only alternative was a private road covered in up to seven feet of snow, with a sharp curve requiring rollers. Steenberg asked the Jacques several times for permission, and they refused. They had lost property valued at over $10,000 in an adverse possession action and were sensitive about allowing others on their land. Steenberg delivered the home on February 15, 1994. That morning, Mr. Jacque told the movers that Steenberg did not have permission to cross. At the Jacques' home, they showed Steenberg's assistant manager an aerial map and plat book proving ownership and repeated their refusal. Asked how much money it would take, Mr. Jacque said it was not a question of money and told Steenberg to use the road. At trial, two employees testified that the assistant manager then told them to get the home in any way they could; the other added that the assistant manager told him to park the company truck so no one could see their route. He denied it. The movers used a bobcat to cut a path through the snow-covered field and hauled the home across the Jacques' land. An officer from the sheriff's department issued the assistant manager a $30 citation.

Issues

1. May an award of nominal damages for intentional trespass to land support an award of punitive damages?
2. If nominal damages support punitive damages for intentional trespass to land, should that holding apply to the defendant or apply only prospectively?
3. Is a jury award of $100,000 in punitive damages excessive when paired with an award of $1 in nominal damages for intentional trespass to land?

Holding

Although the Jacques received no compensatory damages and were awarded only $1 in nominal damages, the jury had discretion to award $100,000 in punitive damages for Steenberg's intentional trespass across their land. The rule applies retroactively to Steenberg, and the $100,000 award is not excessive under the Due Process Clause.