Case 1:18-cv-01011-RMC Document 42 Filed 08/09/19 Page 16 of 19
372 (D.C. 1993)) (emphasis omitted). The purpose of punitive damages is to punish bad acts and
deter repetition. See BMW of N. Am., Inc. v. Gore, 517 U.S. 559, 567 (1996). Courts may award
punitive damages only when the defendant acted with an “evil motive or actual malice.” Daka,
711 A.2d at 98 (citation and quotation marks omitted). An evil motive “goes beyond a mere
intention to be annoying or unpleasant.” Id. (citing Vassiliades v. Garfinckel’s, Brooks Brothers,
Miller & Rhoades, Inc., 492 A.2d 580, 593 (D.C. 1985) (stating that punitive damages are
intended to punish “outrageous conduct which is malicious, wanton, reckless, or in willful
disregard for another’s rights”)). “Direct evidence of malicious intent is not required; malice and
wrongful motive may be inferred from the acts of a party and circumstantial evidence.”
Vassiliades, 492 A.2d at 593.
Having found above that the actions of Messrs Anglin and Ade and Moonbase
Holdings were outrageous and resulted in liability for intentional infliction of emotional distress,
the Court also finds the behavior was sufficiently wanton and willful to justify punitive damages.
Ms. Dumpson requests $1,500,000 in punitive damages, but the Court finds that amount is
excessive and will instead award $500,000, which is more in line with other courts in this
jurisdiction and reflective of the outrageous conduct here. See, e.g., Doe v. De Amigos, No. 111755, 2014 WL 12785325, at *18 (D.D.C. June 10, 2014), report and recommendation
adopted, 2014 WL 2937781 (D.D.C. July 1, 2014) (awarding plaintiff $300,000 in punitive
damages despite a request for $2,000,000 in a case alleging intentional infliction of emotional
distress).
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