In Gasperini v. Center for Humanities, Inc., 518 U.S. 415 (1996), the U.S. Supreme Court upheld an award of compensatory damages against a claim that it was excessive under New York law. The Court ruled that appellate review of a federal trial court's refusal to set aside a jury verdict as excessive is reconcilable with the Seventh Amendment if "appellate control [is] limited to review for 'abuse of discretion.'" Id. at 419.
"An essential characteristic of [the federal court] system is the manner in which, in civil common-law actions, it distributes trial functions between judge and jury and, under the influence -- if not the command -- of the Seventh Amendment, assigns the decisions of disputed questions of fact to the jury." Id. at 432 (citing Byrd v. Blue Ridge Rural Elec. Cooperative, Inc., 356 U.S. 525, 537 (1958)). The Court observed that although trial courts traditionally had broad authority at common law to set aside jury verdicts and to grant new trials, 518 U.S. at 432-433, "appellate review of a federal trial court's denial of a motion to set aside a jury's verdict as excessive is a relatively late, and less secure, development," id. at 434.
Justice Ruth Bader Ginsburg wrote the opinion for the 5-4 Court, which concluded that although the Seventh Amendment does not preclude such appellate review, id. at 436, "within the federal system, practical reasons combine with Seventh Amendment constraints to lodge in the district court, not the court of appeals, primary responsibility for application of [an excessiveness standard]," id. at 438. "Trial judges have the unique opportunity to consider the evidence in the living courtroom context," the Court held, "while appellate judges see only the cold paper record." Id. (citations and internal quotation marks omitted). "If [courts of appeals] reverse, it must be because of an abuse of discretion .... The very nature of the problem counsels restraint .... [Appellate courts] must give the benefit of every doubt to the judgment of the trial judge." Id. at 438-439 (internal quotation marks omitted) (citing Dagnello v. Long Island R. Co., 289 F.2d 797, 806 (CA2 1961)).
Chief Justice William Rehnquist and Justices John Paul Stevens, Antonin Scalia and Clarence Thomas all dissented.