Estrada v. PORT CITY PROPERTIES, INC.
2011 OK 30
| Okla. | 2011Background
- Estrada employed by Hodges Warehouse from 2001 to Sept 2003; he injured January 16, 2003 and underwent multiple doctors’ visits and surgery; he returned to some work in March 2003 but was restricted; he sought workers’ compensation and later hired counsel; Hodges terminated him September 30, 2003; Estrada alleged retaliation for filing a workers’ compensation claim and retaining counsel; trial court initially held no evidence for punitive damages yet submitted that issue to the jury; jury awarded actual damages $76,730 and punitive damages $18,398; on appeal the punitive damages submission was challenged, collateral source evidence was disputed, and actual damages were defended as not excessive; the Oklahoma Supreme Court issued the decision addressing these issues and ordering punitive damages award stricken while upholding collateral source rule and damages verdicts as not excessive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Punitive damages submission proper when no evidence | Estrada argues trial court should not have submitted punitive damages to the jury | Estrada argues jury questions remain; court must submit if any evidence supports it | Erroneous to submit; no evidence supports punitive damages |
| Collateral source rule applicability | Collateral sources like unemployment benefits should not offset damages | Evidence may be used to impeach financial hardship claims | Collateral source rule applies regardless of financial hardship |
| Actual damages not excessive | Damages supported by testimony of loss and mental anguish | Damages were excessive or not fully supported by evidence | Not excessive under the record |
Key Cases Cited
- Sides v. Cordes, Inc., 981 P.2d 301 (Okla. 1999) (punitive-damages framework and threshold findings for jury submission)
- Blythe v. University of Oklahoma, 82 P.3d 1021 (Okla. 2003) (collateral source rule in workers’ compensation context and its incorporation into damages)
- Denco Bus Lines, Inc. v. Hargis, 229 P.2d 560 (Okla. 1951) (collateral source rule—damages not reduced by collateral benefits)
- Wilson v. Hess-Sweitzer & Brant, Inc., 864 P.2d 1279 (Okla. 1993) (standard for employer’s burden in retaliatory-discharge cases)
- Gilbert v. Security Finance Corp. of Oklahoma, Inc., 152 P.3d 165 (Okla. 2006) (upholding constitutionality of 23 O.S. Supp.2002 § 9.1)
- Wilspec Technologies, Inc. v. DunAn Holding Group Co. Ltd., 204 P.3d 69 (Okla. 2009) (punitive-damages framework under 23 O.S. Supp.2002 § 9.1)