In Delacroix v. Doncasters, Inc., No. ED 97375 (Mo. Ct. App. May 7, 2013), the Missouri Court of Appeals reviewed a ruling by a trial court granting the defendant judgment notwithstanding the verdict on the jury’s award of punitive damages against it for the manufacturer of a faulty airplane engine. The jury found that the engine was defective, which caused the plane to crash and its occupants to be killed. The trial court had concluded that the plaintiff’s evidence did not suffice to establish that the defendant-manufacturer had actual knowledge of the defect in the engine it had manufactured. The Court of Appeals reversed, concluding that the evidence did in fact suffice to demonstrate that the defendant had actual knowledge of the defect in its engine.