The Sixth Circuit yesterday reversed an award of punitive damages despite a finding that a corporate defendant committed a tort maliciously. The case involved violations of a non-compete agreement between Chicago Title and ex-employee James Magnuson. After Magnuson moved to First American Title, 30 other Chicago Title employees and several customers switched to First American. An Ohio jury awarded Chicago Title $10.8 million in actual and $32.4 million in punitive damages against First American for tortious interference with Magnuson’s non-compete. The jury predicated the punitive award on a finding of "malice" by First American. But the Sixth Circuit struck the punitive damages award as unconstitutional, holding that the finding of malice did not by itself justify punishment. Chicago Title Ins. Corp. v. Magnuson, No. 05-4411 (6th Cir. May 21, 2007).