Teitel

This appeal arises from a jury verdict in favor of Patricia S. Teitel against First Los Angeles Bank (Bank). Following a jury trial in which Teitel received a verdict of some $9,000 in general damages and $500,000 in punitive damages against Bank, the trial court denied a remittitur motion to alternatively reduce the amount of punitive damages or grant a new trial, but granted Bank’s motion for judgment notwithstanding the verdict and, in so doing, purported to reduce the award of punitive damages from $500,000 to $50,000. Teitel contends that the trial court was without authority to reduce punitive damages by an order granting judgment notwithstanding the verdict, and that the order violated her constitutionally guaranteed right to jury trial. Bank urges us to affirm the trial court judgment on the ground that the original award was excessive as a matter of law. Alternatively, the Bank asks that we order a new trial conditioned on Teitel’s refusal of a remittitur, the motion which was denied by the trial court.

We conclude that the trial court erred in selecting Bank’s motion for judgment notwithstanding the verdict as the vehicle to reduce what it perceived as an…