Honda Motor Co. v. Oberg, 512 U.S. 415 (1994)

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certiorari to the supreme court of oregon

No. 93-644. Argued April 20, 1994—Decided June 24, 1994

After finding petitioner Honda Motor Co., Ltd., liable for injuries respondent Oberg received while driving a three-wheeled all-terrain vehicle manufactured and sold by Honda, an Oregon jury awarded Oberg $5 million in punitive damages, over five times the amount of his compensatory damages award. In affirming, both the State Court of Appeals and the State Supreme Court rejected Honda's argument that the punitive damages award violated due process because it was excessive and because Oregon courts have no power to correct excessive verdicts under a 1910 amendment to the State Constitution, which prohibits judicial review of the amount of punitive damages awarded by a jury "unless the court can affirmatively say there is no evidence to support the verdict." The latter court relied heavily on the fact that the State's product liability punitive damages statute and the jury instructions in this case provided at least as much guidance as those upheld in Pacific Mut. Life Ins. Co. v. Haslip, 499 U. S. 1. The court also declined to interpret Haslip to hold that due process requires the amount of a punitive damages award to be subject to postverdict or appellate review, and noted that Oregon courts are not powerless because they may vacate a judgment if there is no evidence supporting the jury's decision, and because appellate review is available to test the sufficiency of jury instructions.

Held: Oregon's denial of review of the size of punitive damages awards violates the Fourteenth Amendment's Due Process Clause. Pp. 420-435. (a) The Constitution imposes a substantive limit on the size of punitive damages awards. Pacific Mut. Life Ins. Co. v. Haslip, 499 U. S. 1; TXO Production Corp. v. Alliance Resources Corp., 509 U. S. 443. The opinions in these cases strongly emphasized the importance of the procedural component of the Due Process Clause, and suggest that the analysis here should focus on Oregon's departure from traditional procedures. Pp. 420-421. (b) Judicial review of the size of punitive damages awards was a safeguard against excessive awards under the common law, see, e. g., Blunt v. Little, 3 F. Cas. 760, 761-762, and in modern practice in the federal courts and every State, except Oregon, judges review the size of such awards. See, e. g., Dagnello v. Long Island R. Co., 289 F. 2d 797, 799- 800, n. 1. Pp. 421-426.


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