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interference with present employment claim; and (3) affirmed the judgment on
the tortious interference with future employment claim as to liability, but
reversed and remanded it as to damages on the ground that an award on that
claim could be duplicative of any award on the libel claim. The reversal of
the judgment on the libel claim by the Court of Appeals was on the ground that
the District Court erroneously instructed the jury that IBP had the burden of
proving that the allegedly libelous statements were true. The Court of
Appeals in its opinion stated that petitioner must prove that IBP's statements
that he "stole" documents and committed "perjury" were, in fact, false and
that he must establish that IBP was at fault in publishing these statements.
The Court of Appeals held that to recover punitive damages, petitioner, in
addition to proving falsity, must prove by clear and convincing evidence that
IBP's actions in publishing the challenged statements constituted "actual
malice". With respect to the tortious interference with future employment
claims, the Court of Appeals held that if petitioner failed to recover on his
libel claim, the award of damages should be reinstated, but if petitioner
recovered on his libel claim the District Court should then determine to what
extent a recovery for tortious interference with future employment would
duplicate his libel recovery. To the extent of any duplication, the Court of
Appeals held that the award of damages on the tortious interference with
future employment claim should not be reinstated. On remand, the District
Court entered a judgment on the tortious interference with present employment
claim in accordance with the opinion of the Court of Appeals for the Eighth
Circuit, and on April 23, 1987, IBP paid petitioner $983,281.23 on this claim.
This payment was composed of the following amounts:
Compensatory damages $150,000.00
Punitive damages 500,000.00
Costs 1,933.48
Prejudgment interest 48,575.34
Postjudgment interest 282,772.41
Total 983,281.23
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