damages in this lawsuit. The only causes of action remaining are those for improper secondary activity under 29 U.S.C. § 187 and for defamation under Rhode Island common law. Plaintiff may not recover punitive damages on its claim of unlawful secondary activity. See International Bhd. of Elec. Workers v. Foust, 442 U.S. 42, 52, 99 S.Ct. 2121, 60 L.Ed.2d 698 (1979); Morton, 377 U.S. at 260-61, 84 S.Ct. 1253; Amoco Oil Co. v. Local 99, Int’l Bhd. of Elec. Workers, 536 F.Supp. 1203, 1224 (D.R.I.1982). As the LMRA makes clear, plaintiffs recovery for unlawful secondary pressure is limited to compensatory damages. See 29 U.S.C. § 187(b) (“Whoever shall be injured in his business or property ... shall recover the damages by him sustained.... ”); Morton, 377 U.S. at 260, 84 S.Ct. 1253 (<HOLDING>). Accordingly, defendants’ Motions for Summary
holding that conduct must be beyond the fraud which supported compensatory damages to award punitive damages holding that recovery is limited to actual compensatory damages holding that punitive damages do not need to be proportional to compensatory damages holding that under the first amendment where there is no proof of actual malice damages are limited to actual injury which excludes punitive damages but is not limited to outofpocket loss holding that when compensatory damages are nominal a much higher ratio of punitive damages to compensatory damages can be contemplated