Galarneau v. Merrill Lynch, Pierce, Fenner & Smith, Inc. (First Circuit)

The plaintiff in this case was a terminated Merrill Lynch broker. She sued Merrill Lynch, alleging claims for, inter alia, defamation. The jury found for Galarneau on her defamation claim, which was based on her allegation that Merrill Lynch’s statement that she was terminated for “inappropriate bond trading” was maliciously false. The jury awarded $850,000 in compensatory damages and $2.1 million in punitive damages. We were retained to handle the appeal. The First Circuit upheld the compensatory award but reversed the punitive award in its entirety, concluding that the plaintiff had not met the standard for imposing punitive damages.