In State Farm Mutual Automobile Insurance Co. v. Campbell, the United States Supreme Court held that a $145 million punitive damages award violates the Due Process Clause of the Fourteenth Amendment when compensatory damages are merely $1 million. This decision was neither the first of its kind, nor unexpected, considering the Court's trend in recent years. Nonetheless, the Court has not always been so aggressive in its application of the Due Process Clause to punitive damages awards.
Espy, J. Kaz
"Whoa, Slow Down! Applying the Constitutional Brakes to Accelerated Punitive Damages Awards,"
Mercer Law Review: Vol. 55:
2, Article 10.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol55/iss2/10