Law360, New York (March 3, 2015, 10:11 AM EST) -- A few weeks ago, the United States Court of Appeals for the Third Circuit issued an important, 28-page opinion that confirmed a jury verdict, holding former officers and directors of a not-for-profit health care provider in bankruptcy, jointly and severally liable to the facility's creditors — in the amount of $2.25 million — for breach of fiduciary duty in failing to properly oversee and manage the nonprofit entity. Official Comm. of Unsecured Creditors ex rel. Lemington Home for Aged v. Baldwin (In re Lemington Home for Aged), No. 13-2707, at *1 (3d Cir. Jan. 26, 2015). In the same decision, the court upheld punitive damages of $1 million and $750,000 against two of the officers — the nursing home's administrator and chief financial officer — but reversed a punitive damages award against the directors....