Term: 2006
Docket: 05-1256
Philip Morris Usa v. Mayola Williams, Personal Representative Of The Estate Of Jesse D. Williams, Deceased
- Pro
05-1256 PHILIP MORRIS USA V. WILLIAMS DECISION BELOW:127 P3d 1165 LIMITED TO QUESTIONS 1 AND 2 PRESENTED BY THE PETITION. CERT. GRANTED 5/30/2006 QUESTIONS PRESENTED: In this case brought by the widow of a smoker, the jury held Philip Morris liable for fraud and awarded $79.5 million in punitive damages -- 97 times the compensatory damages awarded by the jury. On remand from this Court for reconsideration in light of State Farm Mutual Automobile Insurance Co. v. Campbell, 538 U.S. 408 (2003), the Oregon Supreme Court upheld the trial court's refusal to instruct the jury that it could not punish Philip Morris for harms to nonparties, concluding that a jury may punish for such harms so long as the conduct that caused those harms is similar to the conduct that harmed the plaintiff. Then, construing the evidence in the light most favorable to the plaintiff, the court proceeded to hold that the punitive award was not unconstitutionally excessive, despite concluding that the punitive award was not reasonably related to the harm to the plaintiff. The questions presented, each of which is the subject of a conflict in the lower courts, are: 1. Whether, in reviewing a jury's award of punitive damages, an appellate court's conclusion that a defendant's conduct was highly reprehensible and analogous to a crime can "override" the constitutional requirement that punitive damages be reasonably related to the plaintiffs harm. 2. Whether due process permits a jury to punish a defendant for the effects of its conduct on non-parties. 3. Whether, in reviewing a punitive award for excessiveness, an appellate court is permitted to give the plaintiff the benefit of all conceivable inferences that might support a finding of high reprehensibility even if the jury made no such specific factual findings. LOWER COURT CASE NUMBER: S51805
In the case of Philip Morris USA v. Mayola Williams, the U.S. Supreme Court ruled in favor of Philip Morris, a tobacco company that was sued by Mayola Williams for her husband's death due to lung cancer from smoking. The court held that it is unconstitutional to award punitive damages against a defendant based on harm inflicted on non-parties or individuals who are not involved in the lawsuit. Previously, an Oregon jury had awarded Mrs. Williams $79.5 million in punitive damages after finding that Philip Morris knowingly sold dangerous products and misled the public about their health risks; however, this decision was overturned by the Supreme Court ruling which stated such punishment could only be imposed if those other smokers were parties to this particular lawsuit.
In the dissenting opinion for Philip Morris USA 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 precedent regarding punitive damages. He contended that the jury had been properly instructed according to state law and should have been allowed to consider evidence of harm caused by Philip Morris' conduct beyond just the plaintiff in this case. Furthermore, he disagreed with the majority's view that due process requires juries be prohibited from punishing defendants for injury inflicted on nonparties; instead, he believed such considerations were relevant in determining reprehensibility - one of three guideposts established by previous Supreme Court rulings for assessing reasonableness of punitive damage awards. Finally, Justice Stevens expressed concern over potential implications of this ruling: it could unduly limit states’ abilities to use punitive damages as a tool against harmful corporate behavior.
