After the widow’s husband was killed in an automobile accident, she sued the manufacturer the pickup truck that her husband had been driving, claiming that the truck was defectively and negligently designed. The jury agreed and awarded the widow $235,629 in compensatory damages and $3 million in punitive damages. On appeal, the court held that the punitive damages award was constitutionally excessive and that an award approximately equal to twice the amount of compensatory damages would comport with the requirements of due process. An application of the Gore guideposts revealed that: (1) the manufacturer’s misconduct did not constitute a high degree of reprehensibility, because (a) there was no evidence that a boxed-in or supported B-pillar would have prevented the harm suffered by the husband; (b) there was a good faith dispute over whether B-pillar testing was necessary; and (c) the manufacturer’s wealth had no connection to the harm suffered by the husband; (2) the ratio of punitive to compensatory damages, 13 to 1, was unjustifiably large; and (3) a wide gap existed between the punitive damage award and comparable civil penalties under 49 U.S.C.S. ยงยง 30165(a). Clark v. Chrysler Corp., 436 F.3d 594 (6th Cir. 2006).
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