Honda Motor Co. v. Oberg

517 U.S. 559 (1996)

Yeazell, pp. 323-326


Facts: Honda sold an ATV that injured Oberg.  Oberg sued and was awarded $1 million in compensatory damages and $5 million in punitive damages by the jury.  Honda appealed on the basis that the punitive damage award violated the Fourteenth Amendment since Oregon courts weren’t allowed to review such awards.


Issue: Does the Oregon constitutional prohibition on judicial review of jury punitive damages awards violate the Fourteenth Amendment?


Rule: Procedural laws and rules that undermine common law procedural protections are presumed to violate the Due Process Clause.


Analysis: The Court argues that common law procedural safeguards form a foundation on which modern constitutional Due Process is built.  That means that whatever procedural protections existed at common law must at least be maintained.  In fact, most of the Court’s decisions have built up new protections unknown at common law but required by the Fourteenth Amendment.  The Court finds that Oregon, in effect, “dug under” the foundation and abridged a protection that existed even before the Constitution.


Ginsburg and the Chief argue that the protections afforded to litigants at trial and upon appeal in Oregon are sufficient to satisfy constitutional Due Process.


Conclusion: The judgment is reversed and remanded to reconsider the punitive damage award.


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