The Oyez Project: Economic Activity Issues - Liability, Punitive Damages Decisions

Barnes v. Gorman

May punitive damages be awarded in a private cause of action brought under the Americans with Disabilities Act of 1990 and the Rehabilitation Act of 1973?

No. In an opinion delivered by Justice Antonin Scalia, the Court held that, because punitive damages may not be awarded in private suits brought under Title VI of the 1964 Civil Rights Act, it follows that they may not be awarded in suits brought under the ADA and the Rehabilitation Act. The Court noted that the remedies of the sections of the ADA and the Rehabilitation Act Gorman sued under are coextensive with those available in a private action under Title VI. Under a contract-law analogy, the Court reasoned because Title VI-funding recipients did not, merely by accepting funds, implicitly consent to liability for punitive damages, it followed that they could not be awarded in suits brought under the ADA and the Rehabilitation Act.

BMW v. Gore

Assuming that Gore's punitive damage award was grossly excessive, does the Fourteenth Amendment's due process clause protect BMW from paying the award?

Yes. In a 5-to-4 decision, the Court held that while a state may impose punitive damages to further its interest in deterring unlawful conduct, the Fourteenth Amendment's due process clause prohibits states from imposing grossly excessive punishments on tort-feasors. In the present case, the punitive damage's excessive nature is indicated by the 500 to 1 ratio between the jury's punitive and actual damage awards, the relatively insignificant amount of damage, and the lack of statutory fines that remotely parallel the present award's magnitude. BMW's due process rights were also violated because it could not have possibly anticipated, nor did it receive fair notice, that it might face such a severe punishment.

Browning-Ferris Industries v. Kelco Disposal

No details yet.

Cooper Industries v. Leatherman Tool Grp.

Did the Court of Appeals review the constitutionality of the punitive damages award against Cooper Industries, Inc. under the correct standard?

No. In an 8-1 opinion delivered by Justice John Paul Stevens, the Court held that the Courts of Appeals should apply a de novo standard when reviewing district court determinations of the constitutionality of punitive damages awards. Because the Court of Appeals applied an "abuse of discretion" standard, a less demanding standard, the Court vacated the judgment and remanded the case for a determination on whether the award was grossly excessive under the correct standard.

Honda v. Oberg

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

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.

Pacific Mutual Life Insurance Co. v. Haslip

No details yet.

State Farm Mutual Auto Ins. Co. v. Campbell

Is an award of $145 million in punitive damages, when full compensatory damages are $1 million, excessive and in violation of the Due Process Clause of the Fourteenth Amendment?

Yes. In a 6-3 opinion delivered by Justice Anthony M. Kennedy, the Court held that the punitive award of $145 million was neither reasonable nor proportionate to the wrong committed, and it was thus an irrational, arbitrary, and unconstitutional deprivation of the property of the insurer. The Court reasoned that evidence of dissimilar out-of-state misconduct was an improper basis for punishing the insurer for the limited harm and noted, "few awards exceeding a single-digit ratio between punitive and compensatory damages, to a significant degree, will satisfy due process." Justices Antonin Scalia, Clarence Thomas, and Ruth Bader Ginsburg dissented. Justices Scalia and Thomas argued that the Due Process Clause provides no substantive protections against excessive or unreasonable awards of punitive damages. Justice Ginsburg noted that the decision overstepped states' traditional territory to regulate punitive damages.

Txo Production Corp. v. Alliance Resources Corp.

No details yet.