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|
|Citations||538 U.S. 408 (more)|
|Prior history||Campbell v. State Farm Mutual Automotive Insurance Co., 2001 WL 1246676 (Utah 2001)|
|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.|
|Majority||Kennedy, joined by Rehnquist, Stevens, O'Connor, Souter, Breyer|
|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:
- the degree of reprehensibility of the defendant's misconduct;
- the disparity between the actual or potential harm suffered by the plaintiff and the punitive damages award; and
- the difference between the punitive damages awarded by the jury and the civil penalties authorized or imposed in comparable cases.
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 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.
See also↑Jump back a section
- Campbell v. State Farm Mutual Automotive Insurance Co., 2001 WL 1246676 (Utah 2001).
- Douglas Laycock, "Modern American Remedies: Cases and Materials", Aspen Publishers, Third Edition, pg. 737.
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