SERVICE EMPLOYEES INTERNATIONAL UNION v. COLCORD
Where field representatives for labor union breached fiduciary duties by secretly participating in campaign to decertify the union that employed them, trial court properly awarded as damages the cost of defendant's union salary and benefits during the period in which the breaches occurred. Award as damages of the campaign costs union incurred in its unsuccessful effort to prevent decertification was unsupported by substantial evidence of causation where defendants could have gathered the signatures required to force a decertification election if they had resigned their employment and relied on their own contacts and knowledge of the membership to mount the signature gathering campaign. Where punitive damages were awarded after bench trial, defendant was entitled to reversal so that, if it chose to, trial court could reconsider the amount awarded in light of appellate court's partial reversal of the compensatory damages award.
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