Exxon Shipping Co. v. Baker Case Brief

Facts of the Case

Oil spilled from a tanker. The owners contended that punitive damages were not available against the owners them based solely upon the recklessness of its managerial employee, that the express pollution penalties of the Clean Water Act (CWA),, precluded an additional penalty of punitive damages, and that the punitive award of approximately five times the amount of the compensatory award was excessive. While equally divided concerning whether the owners could be held vicariously liable for punitive damages, the U.S. Supreme Court held that the CWA did not preclude the award but a reduction of the amount of the award was warranted. However, punitive damages in the maritime tort case were not warranted in an amount greater than the amount of the compensatory damages award, and thus the punitive damages were excessive.

Question

Does a drug-detection dog’s alert to the exterior of a vehicle provide an officer with probable cause to conduct a warrantless search of the interior of the vehicle?

CONCLUSION

Maybe and yes. With Justice Samuel Alito taking no part in the decision because he owns Exxon stock, the Court split evenly 4-4 on the issue of whether judges may award punitive damages against a company for employee misdeeds. Therefore, the Court left the Ninth Circuit’s ruling that they can undisturbed, but noted that this affirmation could not be used as precedent because it merely reflected an even split in the Court. On the second issue, a 5-4 majority held that judges are free to create remedies in maritime cases where Congress has not legislated in the area. However, this freedom can be lost if Congress passes legislation restraining such judicial activism. Justice David Souter delivered the opinion of the Court. Justice Antonin Scalia, joined by Justice Clarence Thomas, wrote a concurring opinion, agreeing with the Court’s application of punitive damages precedent but arguing that those prior holdings were in error. Justice John Paul Stevens concurred in part and dissented in part, stating that Congress, not the courts, should be the sole body entrusted with determining the permissibility of punitive damages. Justice Stephen Breyer also concurred in part and dissented in part, arguing that the punitive damages in this case should have been reduced.

Case Information

Citation: 554 US 471 (2008)
Granted: Oct 29, 2007
Argued: Feb 27, 2008
Decided: Jun 25, 2008
Case Brief: 2008