| State Farm v. Campbell | ||||||
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Supreme Court of the United States |
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| Argued December 11, 2002 Decided April 7, 2003 |
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| Full case name | State Farm Mutual Auto Insurance v. Curtis Campbell | |||||
| Docket nos. | 01-1289 | |||||
| Prior history | Campbell v. State Farm Mutual Automotive Insurance Co., 2001 WL 1246676 (Utah 2001) | |||||
| Holding | ||||||
| 145 million dollars of punitive damages, when the compensatory damages are 1 million is excessive and a violation of the Due Process Clause of the Fourteenth Amendment. | ||||||
| Court membership | ||||||
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| Case opinions | ||||||
| Majority | Kennedy, joined by Rehnquist, Stevens, O'Connor, Breyer, Souter | |||||
| Dissent | Scalia | |||||
| Dissent | Thomas | |||||
| Dissent | Ginsburg | |||||
| Laws applied | ||||||
| Eighth Amendment to the United States Constitution | ||||||
State Farm Mutual Automobile Insurance Co. v. Campbell, 538 U.S. 408 (2003), was a case in which the United States Supreme Court held that the due process clause usually limits punitive damage awards to less than ten times the size of the compensatory damages awarded.
The Court reached this conclusion applying guideposts first noted in BMW of North America, Inc. v. Gore, 517 U. S. 559 (1996), requiring courts to consider:
(1) The degree of reprehensibility of the defendant's misconduct,
(2) The disparity between the actual or potential harm suffered by the plaintiff and the punitive damages award.
(3) The difference between the punitive damages awarded by the jury and the civil penalties authorized or imposed in comparable cases.
Contents |
Justices Antonin Scalia and Clarence Thomas adhered to their previously expressed views that the Due Process Clause and Constitution provide no protection against "excessive" punitive damage awards.
Justice Ruth Bader Ginsburg voted to leave intact the decision of the Utah Supreme Court. She expressed her view that the Supreme Court "has no warrant to reform state law governing awards of punitive damages..." She wrote that punitive damage caps should be set in place by legislatures.
The Utah Supreme Court reinstated a $145 million punitive verdict[1] against State Farm, noting that an earlier $100 million judgment had gone unreported to State Farm's corporate headquarters, and that the regional vice president had no plans to report the judgment under review, despite the judgment being substantially based on evidence of national corporate policy.[2]
Ellen Quackenbos was a leading author of the petition for writ of certiorari and the merits briefs on behalf of State Farm in this case. Her thoughts as to how this case should be applied should be given great deference in preparing cert petitions regarding constitutional challenges to punitive damages awards.