Phillip Morris U.S.A. v. Williams
549 U.S. 346, 127 S.Ct. 1057 (2007)
- Williams was a smoker. After he died, his estate sued the cigarette maker (Phillip Morris) for negligence and deceit.
- Williams argued that Phillip Morris hid the fact that smoking was a health hazard.
- The Trail Court found for Williams and awarded $821k in compensatory damages, and $79.5M in punitive damages. Phillip Morris appealed.
- The punitive damages were in part based on the idea that lots of other people out there had died from smoking as well.
- Phillip Morris argued that this was unfair because those other people (or their estates) could bring lawsuits and get their own damages.
- The Oregon Supreme Court affirmed. Phillip Morris appealed.
- The US Supreme Court overturned the punitive damages award.
- The Court found that due process bars punitive damages for harm caused to individuals not involved in the litigation.
- Due process requires that Phillip Morris be allowed to present a defense, but how could they defend themselves against someone who wasn’t even in court suing them?
- The Court found that it was impossible to know exactly how many people were smoking because of Phillip Morris’ negligence. Therefore it was unfair to estimate a damage amount.
- BMW of North America v. Gore (517 U.S. 559 (1996)), suggested a three-part test in determining whether a damage award violated due process:
- The degree of reprehensibility of the defendant’s conduct.
- The ratio or harm to the compensatory damages awarded.
- A comparison of the punitive damages award to civil or criminal penalties that could be imposed for comparable misconduct.