OPINION
Opinion by Justice FRANCIS.
Rodney R. Elkins sued Telecheck Services, Inc. after various merchants declined his checks after Telecheck disapproved them. Following a three-day trial, a jury found in Elkins's favor on his negligence, defamation, and Federal Fair Credit Reporting Act (FCRA) claims. The jury awarded actual damages on each cause of action and also awarded $50,000 in exemplary damages. After a separate hearing, the trial court determined...
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