Quang v. Tran
After jury trial in this defamation action, judgment was entered on a special verdict for $250,000 compensatory and $100,000 punitive damages in favor of plaintiff Lieu Minh Quang (Quang) against defendant Neil Tran (Tran) and his publication (the Nang Moi newspaper or magazine). The trial court denied Tran's motion for new trial claiming excessive damages. (Code Civ. Proc., 657; all further statutory references are to this code unless noted.) Tran appeals, contending the $200,000 in compensatory damages awarded for negligent infliction of emotional distress was excessive and unsupported by the evidence. Alternatively, Tran contends the compensatory damages award of $250,000 for both defamation and infliction of emotional distress must be reduced by $50,000 to prevent an alleged double recovery. court have reviewed the record and conclude that the award of damages for negligent infliction of emotional distress is adequately supported by the evidence. We further conclude that the verdicts on that point contained elements not contained within the libel award, such that there was no award of duplicative damages as a matter of law. Court affirm the judgment.
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