MATTHEW T. WINTHER TRACEY WINTHER v. UNITED STATES STEEL CORPORATION
The Eleventh Circuit vacated a district court's grant of judgment as a matter of law on claims of wantonness and punitive damages, finding sufficient evidence for a jury to find U.S. Steel acted with reckless disregard for the Winthers' property rights. The court affirmed the denial of U.S. Steel's cross-appeal regarding causation, ruling that expert testimony was not required to prove the developer's activities caused erosion and debris damage.