Karl Oberg was driving an all-terrain vehicle when it overturned, causing him severe, permanent injuries. The jury in his trial assessed almost $1 million in compensatory damages, and an additional $5 million in punitive damages. A 1910 amendment to the Oregon state constitution prohibited judicial review of jury awards.

Question:

Does the Oregon prohibition on judicial review of jury awards violate the Due Process Clause of the 14th Amendment?

Conclusion:

Yes. The denial of judicial review creates the possibility that juries might make arbitrary and excessive awards without offering a way to adjust them. The common-law practice of allowing judicial review for jury awards is important in ensuring that juries do not ignore guidelines.

Decisions

Decision: 7 votes for Honda, 2 vote(s) against
Legal provision: Due Process

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