## Facts

- Best Beers of Bloomington, Inc. (Best Beers) was an Indiana beer wholesaler that had distributed Miller Brewing Company’s (Miller’s) products under a long-running relationship dating back to a 1950 distributorship agreement.
- Miller distributed beer in Indiana through independent wholesalers and was subject to Indiana’s beer wholesaler termination statute, Ind. Code § 7.1-5-5-9, which limited termination and required statutory procedures such as “good cause” and notice protections.
- The relationship deteriorated, and Miller terminated Best Beers as a distributor.
- At trial, Best Beers presented evidence that Miller manufactured or fabricated accusations to create grounds to terminate the distributorship.
- Best Beers sued for wrongful termination and obtained a judgment including compensatory damages and punitive damages.
- On appeal, the Indiana Court of Appeals left the compensatory award intact but vacated the punitive damages award.
- Both parties sought transfer to the Indiana Supreme Court, which reviewed (among other things) jury-instruction and statutory-interpretation questions and whether punitive damages can be awarded in this contract-based dispute.

## Issues

1. Did the trial court err by refusing Miller’s tendered jury instruction concerning the beer wholesaler Termination Statute?
2. Did the Court of Appeals misinterpret the Termination Statute governing termination of a brewer–wholesaler agreement?
3. Are punitive damages available in this action, where the recovery rests on breach of the distributorship relationship and statutory limits on termination?
4. Did admission of an irrelevant document require reversal?

## Decision

- The Indiana Supreme Court affirmed the judgment awarding compensatory damages to Best Beers for Miller’s unlawful termination under the Termination Statute.
- The Court held that punitive damages are not recoverable for a breach of contract claim; to obtain punitive damages, a plaintiff must plead and prove a separate, independent tort for which Indiana law allows punitive damages.
- Because Best Beers’ recovery rested on contract-based rights (including statutory protections tied to the distributorship agreement) and not on a separate tort supporting punitive damages, the punitive damages award could not stand.
- The Court did not order a retrial on punitive damages; it confirmed that punitive damages were unavailable on these claims.
- The Court found no reversible error based on the challenged evidentiary ruling regarding the irrelevant document.

## Legal Principles

- Punitive damages are not allowed in a breach of contract action in Indiana.
- A plaintiff seeking punitive damages must plead and prove an independent tort of a type for which Indiana law permits punitive damages; proof of an intentional or bad-faith breach, without more, is not enough.
- Indiana’s beer wholesaler Termination Statute restricts termination of a brewer–wholesaler relationship and provides statutory requirements (including “good cause” and procedural protections) that can support compensatory relief when violated.
- A trial court’s refusal of a proposed jury instruction warrants reversal only when the refusal results in prejudice and the jury is not otherwise properly instructed on the governing law.
- Admission of irrelevant evidence does not require reversal unless it affects the substantial rights of a party.

## Conclusion

Miller Brewing Co. v. Best Beers of Bloomington, Inc. held that Best Beers could recover compensatory damages for Miller’s wrongful termination of a beer distributorship in violation of Indiana’s Termination Statute, but it could not recover punitive damages because Indiana bars punitive damages for breach of contract absent a separate, recognized tort supporting such relief.


Miller Brewing Co. v. Best Beers of Bloomington, Inc., 608 N.E.2d 975 (1993)