Case Caption: RANGER AMERICAN OF THE V.I. ,INC. v. PEDROCase Number: SCT-CIV-2024-0119Date: 09/10/2025Author: Willocks, Harold W.L. Citation: 2025 VI 20Summary: In the employer’s appeal from a judgment entered against it on the plaintiff’s claim of wrongful discharge in violation of the Virgin Islands Wrongful Discharge Act, 24 V.I.C. § 76, reflecting the jury’s verdict awarding plaintiff $25,000 in economic losses (lost wages), $0 damages for non-economic losses, and $275,000 in punitive damages, the plaintiff’s procedural argument–that this appeal should be dismissed as untimely because no good cause existed to warrant an extension for the employer to file its notice of appeal–is deemed waived. On the merits, while the employer challenges the punitive damages award on the ground that it was an unconstitutionally excessive verdict and asserts that this Court should reduce it to an amount that conforms to the requirements of the Due Process Clause, the employer did not challenge the jury’s finding that it was liable for wrongfully terminating the plaintiff from his part-time job under circumstances warranting an award of punitive damages. As a result, applying the analysis expressed in BMW of North America, Inc. v. Gore, 517 U.S. 559 (1996) and State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003), the Court concludes that under the specific facts of this case, the maximum constitutionally permissible punitive damages award is $25,000, representing a 1:1 punitive-to-compensatory damages ratio. This amount (1) acknowledges the jury’s unchallenged finding that the employer was liable for wrongful termination under circumstances warranting punitive damages; (2) advances the Virgin Islands’ legitimate interest in punishing and deterring termination of employment without explanation, while also considering the minimal to non-existent level of reprehensibility in this particular employer’s conduct and the Virgin Islands’ corresponding slight interest in punishment and deterrence; and (3) remains consistent with the punitive damages awarded in Atlantic Human Res. Advisors, LLC v. Espersen, 76 V.I. 583 (V.I. 2022), where the conduct at issue was significantly more reprehensible than the employer’s conduct in this matter.Attachment: Open Document or Opinion