Helmer

PlaintiffKevin Helmer filed suit against defendants Bingham Toyota Isuzu and Bob Clark, his former employer and supervisor, for promissory fraud. He alleges that he was fraudulently induced to leave a prior job due to false promises made to him by Clark. A jury found in Helmer’s favor, awarding him $450,913 in compensatory damages and $1.5 million in punitive damages. Later, the court reduced the punitive damage award to $675,000.

Bingham appeals the judgment, arguing that 1) Helmer did not prove the elements of a cause of action for promissory fraud; 2) the award of compensatory damages was excessive; and 3) the punitive damages award was excessive and not supported by the evidence. Helmer also appeals, contending that the trial court erred in reducing the amount of punitive damages.

In the published portion of this opinion, we uphold the jury’s award of economic damages for the lost income Helmer suffered as a result of his leaving a secure job due to Clark’s false promises regarding the monthly compensation he would earn at Bingham. In doing so, we hold that future lost income is recoverable by an employee pursuing a claim of promissory fraud against an employer who…