F.3d, 2021 WL 2148494

Where compensatory damages were $47,300 and jury awarded punitive damages of $1,000,000, district court’s remittitur to $236,500 was reversed; Appeals Court awarded $425,700 based on a 9-1 ratio with compensatory damages, due to reprehensibility of defendant’s conduct—dropping unconscious plaintiff face-first onto concrete.

Trial court properly allowed vocational rehabilitationist to rely on medical records, reports, and testimony about plaintiff’s medical condition to opine of effect his medical condition might have on his vocational outlook.