Term: 2008
Docket: 07-1216
Philip Morris Usa Inc. v. Mayola Williams, Personal Representative Of The Estate Of Jesse D. Williams, Deceased
- Pro
07-1216 PHILIP MORRIS USA V. WILLIAMS DECISION BELOW: 176 P.3d 1255 LIMITED TO QUESTION 1 PRESENTED BY THE PETITION. DISMISSED AS IMPROVIDENTLY GRANTED. CERT. GRANTED 6/9/2008 QUESTION PRESENTED: When this case was last before it, this Court reversed the decision of the Oregon Supreme Court and held that due process precludes a jury from imposing punitive damages to punish for alleged injuries to persons other than the plaintiff. Philip Morris USA v. Williams, 127 S. Ct. 1057, 1065 (2007). This Court then remanded the case to the Oregon Supreme Court with directions to “apply the [constitutional] standard we have set forth.” Ibid. On remand, however, the Oregon Supreme Court refused to follow this Court’s directive. Instead, the Oregon court “adhered to” the judgment that this Court had vacated because it found that Philip Morris had procedurally defaulted under state law and thereby forfeited its claim of federal constitutional error. App., infra, 22a. The questions presented—the second of which was accepted for review but not reached when this case was last before the Court—are: 1. Whether, after this Court has adjudicated the merits of a party’s federal claim and remanded the case to state court with instructions to “apply” the correct constitutional standard, the state court may interpose—for the first time in the litigation—a state-law procedural bar that is neither firmly established nor regularly followed. 2. Whether a punitive damages award that is 97 times the compensatory damages may be upheld on the ground that the reprehensibility of a defendant’s conduct can “override” the constitutional requirement that punitive damages be reasonably related to the plaintiffs harm. LOWER COURT CASE NUMBER: S051805
In the 2008 case Philip Morris USA Inc. v. Mayola Williams, the U.S. Supreme Court ruled in favor of tobacco company Philip Morris, overturning a $79.5 million punitive damages award to Mayola Williams, whose husband died from smoking-related lung cancer. The court held that it was unconstitutional for juries to punish defendants like Philip Morris by considering harm suffered by non-parties - people not involved in the lawsuit - when determining punitive damage amounts; they could only consider actual harm caused to the plaintiff(s). This decision emphasized that due process requires each party have an opportunity to defend against charges and potential penalties specifically related to their conduct towards them.
In the dissenting opinion for Philip Morris USA Inc. v. Mayola Williams, Justice John Paul Stevens argued that the majority's decision to overturn a punitive damages award against Philip Morris was based on an incorrect interpretation of Oregon law and a misunderstanding of constitutional principles regarding punitive damages. He contended that juries should be allowed to consider harm caused to non-parties when determining punitive damage awards as it provides them with necessary context about the defendant’s conduct. Furthermore, he believed this case did not involve any unconstitutional action by the jury or state courts because they were simply following established legal precedent in their jurisdiction at that time. The dissent also criticized the majority for intervening in matters traditionally left up to individual states, such as setting standards for punishment in civil cases.
