Steven Moulds

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For the third time in eleven years, the United States Supreme Court imposed constitutional limits on punitive damage awards. In Philip Morris USA v. Williams, the Court, in a 5-4 decision, held that punitive damages cannot be used to punish a defendant for injuries that the defendant infficted upon nonparties to the case. However, the Court also held that injuries to nonparties can be considered when determining the reprehensibility of the defendant's conduct under the "Gore guideposts." Nevertheless, this decision is important for trial lawyers for what the Court did not hold. Once again, the Court passed on the opportunity to decide how much was too much when determining the size of punitive damage awards.

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