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State Farm v. Campbell

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Title: State Farm v. Campbell  
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Subject: Fourteenth Amendment to the United States Constitution, Laurence Tribe, BMW of North America, Inc. v. Gore, Insurance bad faith, Philip Morris USA v. Williams, Tobacco politics
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State Farm v. Campbell

State Farm v. Campbell
Supreme Court of the United States
Argued December 11, 2002
Decided April 7, 2003
Full case name State Farm Mutual Auto Insurance v. Curtis Campbell
Docket nos. 01-1289
Citations 538 more)
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
Case opinions
Majority Kennedy, joined by Rehnquist, Stevens, O'Connor, Souter, Breyer
Dissent Scalia
Dissent Thomas
Dissent Ginsburg
Laws applied
U.S. Const. amend. VIII

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; and
  3. the difference between the punitive damages awarded by the jury and the civil penalties authorized or imposed in comparable cases.

Dissents

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.

Procedural History

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]

See also

References

External links

  • Text of State Farm v. Campbell, 538 U.S. 408 (2003) is available from:  Cornell LII 


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