State Farm Mutual Automobile Ins. Co. v. Campbell
Campbell sued State Farm for damages arising from its decision to try a third-party automobile accident case in which Mr. Campbell was the defendant, rather than accepting offers to settle for the policy limits of Campbell's insurance policy. The jury found in Campbell’s favor, awarding $911.25 in out-of-pocket costs, $2.6 million in compensatory damages, and $145 million in punitive damages. State Farm filed several post-verdict motions challenging the jury verdict, which the trial court rejected. As a condition of denying State Farm's motion for a new trial, however, the trial court remitted the compensatory damage award from $2.6 million to $1 million and the punitive damage award from $145 million to $25 million. The Supreme Court of Utah upheld the jury’s punitive damages award of $145 million, holding that remittitur was improper.
Questions Presented:
1. Whether the United States Constitution allows a state court to impose and inflate punitive damages based on the defendant's purely out-of-state conduct or its aggregate worldwide
”wealth” and profits.
2. Whether the United States Constitution requires that juries be instructed on the federal constitutional limitations on their ability to assess punitive damages.
