Albuquerque Concrete Coring Co. v. Pan am World Services Inc‪.‬

FROST, Justice. This is an appeal from a judgment awarding compensatory and punitive damages to Plaintiff-Appellee Albuquerque Concrete Coring
Company, Inc. (ACC) against Defendant-Appellant Pan Am World Services, Inc. (Pan Am). Pan Am disputes only the district court's
award of punitive damages. This case raises two issues: (1) whether there is substantial evidence of corporate authorization
or ratification to support the award of punitive damages, and (2) whether Pan Am may be liable for punitive damages based
upon the misconduct of its agent acting within his scope of employment in a "managerial capacity" and, if so whether there
is substantial evidence of such corporate participation as to support the award of punitive damages. We affirm.