James Patton v. Target Corporation

I. Factual and Procedural History

Plaintiff-Appellee James Patton (“Patton”) sued Defendant- Appellee Target Corp. (“Target”) in federal district court for asserted violations of the Uniformed Services Employment 1 This “Background” section constitutes our statement of the relevant facts and explanation of the “nature of the controversy in which the ques- tion[ ] arose.” OR. REV. STAT. § 28.210. PATTON v. TARGET CORPORATION 12219 and Reemployment Rights Act (“USERRA”), 38 U.S.C. §§ 4301-4335, and for wrongful discharge under Oregon law. Patton alleged that Target demoted and later fired him because of his service in the National Guard. The jury found in Target’s favor on the USERRA claim, but found in Pat- ton’s favor on the state law claim. It awarded Patton $17,950 in economic damages, $67,000 in noneconomic damages, and $900,000 in punitive damages.

The district court indicated that it expected a substantial post-verdict dispute between the parties regarding the validity and amount of the punitive damages award. Shortly after the verdict, however, Patton and Target reached a settlement and jointly moved the court to approve a stipulated judgment…