## Facts

- Ronald Lent worked for Huntoon Business Machines, Inc. for about thirteen years, ultimately as service manager.
- When hired, Lent disclosed he was on probation for a criminal conviction and had been confined to base while in the Air Force for a minor offense.
- In 1977, Lent told H.J. Huntoon he planned to move to Florida after selling his house and would train a replacement; Huntoon terminated him shortly thereafter.
- Lent did not move, and he started a competing business-equipment sales and service company in the same general market.
- Huntoon Business Machines, Inc., through H.J. Huntoon, circulated a letter on corporate letterhead to numerous customers; Lent sued for libel based on the letter.
- Lent also alleged H.J. Huntoon made oral statements to customers after the letter’s publication, supporting a slander claim, including assertions that Lent had an extensive criminal record, had stolen from his employer, was incompetent, and was untrustworthy.
- Lent alleged the communications caused lost customers and personal distress.

## Issues

1. Whether the evidence was sufficient to support liability for libel and slander in light of the defenses of truth and privilege.
2. Whether the evidence supported the compensatory damages award, including any claimed economic loss.
3. Whether punitive damages were properly submitted to the jury and supported by evidence of malice, and whether the amount required remittitur.
4. Whether alleged errors in jury instructions warranted reversal where defendants did not object to the charge.

## Decision

- The Vermont Supreme Court affirmed the judgment for Lent.
- The court upheld the jury’s finding of defamation and the awards of $15,000 compensatory damages and $25,000 punitive damages.
- The court sustained the trial court’s denial of defendants’ motions for directed verdict, judgment notwithstanding the verdict, new trial, and remittitur.
- The court concluded the jury instructions were essentially correct and noted defendants made no objection to the charge.

## Legal Principles

- Truth is a complete defense to defamation, but the jury may reject the defense if the evidence supports a finding that the statements were not true as made.
- A qualified privilege for business-related communications may apply, but it can be defeated or lost if the communication is made in bad faith or with malice; whether privilege applies or is abused may be treated as a jury question under proper instructions.
- Compensatory damages in defamation may be awarded for reputational harm and related distress when supported by the evidence, and an appellate court will not reweigh the jury’s assessment if the record supports it.
- Punitive damages are permissible in defamation when the evidence supports a finding of malice under state law; appellate review is deferential to the jury and trial court absent legal error.

## Conclusion

The court affirmed a jury verdict finding a former employer and its owner liable for defamatory written and oral statements made to customers in a competitive business setting, concluding that the evidence supported rejection of truth and privilege defenses and supported both compensatory and punitive damages.


Lent v. Huntoon, 470 A.2d 1162 (Vt. 1983)