Facts of the Case

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.