Honda Motor Co. v. Oberg

In Honda Motor Co. v. Oberg, 512 U.S. 415 (1994), the U.S. Supreme Court held that the Due Process Clause of the U.S. Constitution requires judicial review of the size of punitive awards, and a state constitutional provision limiting such review was unconstitutional.

Justice John Paul Stevens wrote the opinion for the 7-2 Court. He held that:

An amendment to the Oregon Constitution prohibits judicial review of the amount of punitive damages awarded by a jury "unless the court can affirmatively say there is no evidence to support the verdict." The question presented is whether that prohibition is consistent with the Due Process Clause of the Fourteenth Amendment. We hold that it is not.

This decision relied on English common law decisions from the early 1990s, and built on two other decisions in the early 1990s that limited the size of punitive damages:

• Pacific Mut. Life Ins. Co. v. Haslip, 499 U.S. 1 (1991)

• TXO Production Corp. v. Alliance Resources Corp., 509 U.S. 443 (1993)

In an unusual liberal-conservative coalition in dissent, Justice Ruth Bader Ginsburg dissented, which was joined by Chief Justice William Rehnquist.

Note that the U.S. Supreme Court has held that the Constitution imposes certain limits on punitive damages, in respect both to procedures for awarding punitive damages and to amounts forbidden as "grossly excessive."