Philip Morris U.S.A. v. Williams, 127 S. Ct. 1057 (2007)

Issue: Whether the Constitution’s Due Process Clause permits a jury to base punitive damages on its desire to punish the defendant for harming individuals not before the court.

Facts: Williams’ widow sued Philip Morris, the manufacturer of Malboro for negligence and deceit in causing the death of her husband. At trial, the court did not accept Philip Morris’ instruction that “the jury could not seek to punish Philip Morris for injury to other persons not before the court.” However, it allowed the plaintiff’s attorney to consider all those in the state of Oregon who will die from cigarettes that Philip Morris makes.

Procedural Posture: “The jury found that Williams’ death was cause by smoking; that Williams smoked [ ] because he thought it was safe to do so; and that Philip Morris knowingly and falsely led him to believe that this was so.” The jury awarded compensatory damages of $821,000 and $79.5 million in punitive damages. The Oregon Supreme Court upheld the judgment.

Holding: A punitive damage award such as this “amounts to a taking of “property” from the defendant without due process.”

Reasoning: The Due Process Clause does not allow a State to use a punitive damage award to punish a defendant for injury that it inflicts upon nonparties. Relied on BMW of North America, Inc. v. Gore and State Farm Mutual Automobile Insurance Co. v. Campbell.

Judgment: The Supreme Court vacated the Oregon Supreme Court’s judgment and remanded the case for further proceedings.