Pacific Mut. Life Ins. Co. v. Haslip
In Pacific Mut. Life Ins. Co. v. Haslip, 499 U.S. 1 (1991), the U.S. Supreme Court upheld a punitive damage award, but indicated that the Due Process Clause does impose an outer limit on large awards of punitive damages.
The Court expressed concerns about "unlimited jury discretion -- or unlimited judicial discretion for that matter -- in the fixing of punitive damages." But the Court refused to "draw a mathematical bright line between the constitutionally acceptable and the constitutionally unacceptable." Regarding the components of "the constitutional calculus," the Court simply referred to "general concerns of reasonableness and [the need for] adequate guidance from the court when the case is tried to a jury."
- We are aware that the punitive damages award in this case is more than 4 times the amount of compensatory damages, is more than 200 times the out-of-pocket expenses of respondent Haslip, see n. 2, supra, and, of course, is much in excess of the fine that could be imposed for insurance fraud under Ala. Code §§ 13A-5-11 and 13A-5-12(a) (1982), and Ala. Code §§ 27-1-12, 27-12-17, and 27-12-23 (1986). Imprisonment, however, could also be required of an individual in the criminal context. While the monetary comparisons are wide and, indeed, may be close to the line, the award here did not lack objective criteria. We conclude, after careful consideration, that in this case it does not cross the line into the area of constitutional impropriety. Accordingly, Pacific Mutual's due process challenge must be, and is, rejected.
TXO Production Corp. v. Alliance Resources Corp., 509 U.S. 443 (1993).
- 499 U.S. at 18.