State Farm Mutual Automobile Insurance Co. v. Campbell
2003 United States Supreme Court case / From Wikipedia, the free encyclopedia
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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 and that punitive damage awards of four times the compensatory damage award is "close to the line of constitutional impropriety".[1]
Quick Facts State Farm Mutual Automobile Insurance Co. v. Campbell, Argued December 11, 2002 Decided April 7, 2003 ...
State Farm Mutual Automobile Insurance Co. v. Campbell | |
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Argued December 11, 2002 Decided April 7, 2003 | |
Full case name | State Farm Mutual Auto Insurance v. Curtis Campbell |
Docket no. | 01-1289 |
Citations | 538 U.S. 408 (more) 123 S. Ct. 1513; 155 L. Ed. 2d 585; 2003 U.S. LEXIS 2713 |
Case history | |
Prior | 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 | |
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Case opinions | |
Majority | Kennedy, joined by Rehnquist, Stevens, O'Connor, Souter, Breyer |
Dissent | Scalia |
Dissent | Thomas |
Dissent | Ginsburg |
Laws applied | |
U.S. Const. amend. XIV |
Close
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.