BMW
of
517
Yeazell,
pp. 326-328
Facts: BMW sold Gore a car that
had been repainted due to acid rain damage.
Gore found out and sued and won compensatory damages of $4,000 and punitive
damages of $4,000,000 based on the theory that there were about 1,000 other
people who bought similarly repainted cars.
The Alabama Supreme Court reduced the punitive damages award to
$2,000,000. BMW appealed to the United
States Supreme Court.
Issue: Was the punitive damage
award in the case unconstitutional excessive?
Rule: The constitutionality of punitive
damages awards will be judged by:
1. The degree of
reprehensibility of the defendant’s conduct
2. The disparity
between the actual harm done, as found by the jury, and the punitive damages
award, and
3. The difference
between the punitive damage remedy and civil or criminal fines imposed by statute
or in similar cases at trial.
Analysis: The Court finds that BMW’s
conduct was not that reprehensible, and in fact is permissible in many other
states. The Court especially notes that
BMW’s conduct did not threaten anyone’s health or safety.
The
Court finds that a punitive damages award that is 500 times the compensatory damages
award is too high, though the Court declines to draw a line saying what “multiplier”
is constitutionally acceptable.
Finally,
the Court notes that by statute, the maximum penalty for violation of
Conclusion: The Court reverses the punitive
damages award.