On August 13, a Florida District Court of Appeals affirmed in part and reversed in part a judgment against a national bank (defendant) awarding a payment processor approximately $2 million in compensatory damages and $5 million in punitive damages. The judgment, based on a jury verdict, awarded punitive damages as a result of the conduct of the bank’s relationship manager, who negligently misrepresented to a payment processor (plaintiff) that the account of the bank’s customer, a check authorization service, was in good standing when really the bank had previously terminated the relationship. On appeal, the court found that the relationship manager was considered a mid-level employee with limited managerial authority. Therefore, the appeals court determined that the defendant could not be held directly liable for his conduct, stating that “[the employee] was not a managing agent for purposes of imposing direct liability for punitive damages,” and “the trial court erred in denying [the defendant’s] motion for judgment notwithstanding the verdict on [the plaintiff’s] punitive damage claim.”