Jacque v. Steenberg Homes, Inc. case brief

Jacque v. Steenberg Homes, Inc.

Jacque (P) sued after Steenberg Homes (D) delivered a mobile home to its buyer by towing it across land owned by Jacque without Jacque’s permission.

Facts
Steenberg Homes had agreed to deliver a mobile home to its buyer. The easiest method of delivery consisted of towing the home across Jacque’s land. The only alternative route was a winding, snow-covered road. Using that road would have required Steenberg Homes to use special equipment to ensure the safety of the home and thereby incur additional costs. Prior to delivery, Steenberg Homes had unsuccessfully requested permission from Jacque to use Jacque’s land. Jacque refused in part because he had lost land through adverse possession some years before and so was reluctant to allow strangers access to the land. On the morning of the delivery, an assistant manager for Steenberg Homes made a final offer to pay Jacque for use of this land, but Jacque refused once again. The assistant manager then ordered workers to tow the home across the land, Jacque’s refusal notwithstanding. At trial, the court awarded Jacque nominal damages of one dollar and punitive damages of $100,000.

Issue
May a court award punitive damages for trespass even though the facts would otherwise support only nominal damages? If so, are the punitive damages of $100,000 in this case excessive?

Holding
The court may award such punitive damages. The punitive damages of $100,000 in this case are not excessive.

Analysis
In many cases, the harm of trespass consists not of direct damage to the land but of invading the landowner’s right to exclusive use of that land. Limiting relief to nominal damages would undermine this crucial right, as any tres- passer could then infringe upon the land while incurring only a slight penalty. Repeated trespasses might ultimately amount to the adverse possession that had worried Jacque. The state must therefore support the property rights of individuals by imposing punitive damages sufficient to deter trespass. Fur- thermore, punitive damages encourage landowners to rely on the courts for relief rather than taking the law into their own hands.