Philip Morris USA v. Williams

Facts of the Case

Plaintiff, Jesse Wiiliams’ widow, brought suit in an Oregon state court against defendant Philip Morris USA, the tobacco company that manufactured the brand of cigarettes that Williams had favored. During the trial, the plaintiff’s attorney told the jury to think about how many other Oregon smokers there might have been whose deaths might be traced to the company’s products. The trial court did not accept a jury instruction, proposed by the tobacco company, that would have told the jury that it was permissible to consider the extent of harm suffered by others in determining the amount of punitive damages, but the jury was not to punish the company for the impact of its alleged misconduct on other persons. Instead, the court instructed the jury that punitive damages were awarded against a defendant to punish misconduct and to deter misconduct and were not intended to compensate the plaintiff or anyone else for damages caused by the defendant’s conduct. Subsequently, the jury found that smoking had caused Williams’ death, and that Philip Morris had knowingly and falsely led Williams to believe that it was safe to smoke. With respect to the plaintiff’s deceit claim, the jury awarded about $821,000 in compensatory damages and $79.5 million in punitive damages. Philip Morris challenged the judgment, asserting that the jury was impermissibly permitted to calculate punitive damages based on harm to parties who were not parties to the litigation.

Question

1) Can a court’s determination that a defendant’s conduct was highly reprehensible and analogous to crime override the constitutional requirement that punitive damages must be reasonably related to the harm to the plaintiff?2) Does due process permit a jury to punish a defendant for the effects of its conduct on non-parties?

CONCLUSION

1) Unconsidered and 2) no. The Court ruled 5-4 that the Constitution’s Due Process Clause forbids a State to use a punitive damages award to punish a defendant for injury that it inflicts upon nonparties. The opinion by Justice Stephen Breyer held that it would be unfair to allow courts to award punitive damages for harm done to strangers to the litigation, because defendants cannot defend themselves against such limitless and arbitrary charges. The Court did note that risk of harm to the general public can be taken into account as a component of the reprehensibility of the defendant’s actions. Highly reprehensible actions may warrant a larger award of punitive damages, but the award cannot be increased as a direct result of harms inflicted on non-parties. The Court decided not to rule on the question of whether the $79.5 million award was excessive.

Case Information

  • Citation: 549 US 346 (2007)
  • Granted: May 30, 2006
  • Argued: Oct 31, 2006
  • Decided Feb 20, 2007