Philip Morris USA v. Williams
Encyclopedia
Philip Morris USA v. Williams, 549 U.S. 346
(2007), was a decision by the Supreme Court of the United States
, which held that the due process
clause of the Fourteenth Amendment
bars punitive damages
for harm caused to individuals not involved in the litigation.
Mayola Williams, the widow of Jesse D. Williams, who died of smoking-related lung cancer
, sued Philip Morris USA
, a cigarette manufacture
r, for fraud
based on Philip Morris advertisements and sponsored studies that made cigarettes seem less dangerous than they actually were. At trial
, the jury found for Williams and awarded her $821,485.50 in compensatory damages and $79.5 million in punitive damages. The trial court found that the compensatory damages exceeded the state cap and the punitive damages were "grossly excessive". It reduced the respective amounts to $521,485.50 and $32 million.
On appeal, the Oregon Court of Appeals
reversed and reinstated the $79.5 million judgment. Following the "guideposts" established in BMW of North America, Inc. v. Gore
, the Court of Appeals examined whether the punitive damages were appropriate based on (1) the degree of reprehensibility of the conduct, (2) the disparity between the actual harm and the punitive damages, and (3) the difference between the punitive damages and civil penalties allowed in similar cases. While determining the reprehensibility of Philip Morris's actions, the court considered the length of the misinformation campaign and the number of people it had reached, concluding that its actions were so reprehensible that they justified punitive damages 97 times greater than the actual damages. The Oregon Supreme Court
denied review.
The Supreme Court of the United States then granted certiorari
, vacated
the Court of Appeals' judgment, and remanded the case to the Court of Appeals for that court to reconsider the amount of the punitive damages award in light of State Farm v. Campbell. The Court of Appeals again reinstated the $79.5 million judgment. On appeal, the Supreme Court of Oregon affirmed, also holding that the courts can consider evidence of similar conduct to other people in Oregon–even those not party to the law suit–when awarding punitive damages.
The counsel for petitioner Philip Morris USA was Andrew L. Frey and Mayer Brown. The counsel for respondent Williams was Robert S. Peck; Center for Constitutional Litigation, P.C.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2007), was a decision by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
, which held that the due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
clause of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
bars punitive damages
Punitive damages
Punitive damages or exemplary damages are damages intended to reform or deter the defendant and others from engaging in conduct similar to that which formed the basis of the lawsuit...
for harm caused to individuals not involved in the litigation.
Mayola Williams, the widow of Jesse D. Williams, who died of smoking-related lung cancer
Lung cancer
Lung cancer is a disease characterized by uncontrolled cell growth in tissues of the lung. If left untreated, this growth can spread beyond the lung in a process called metastasis into nearby tissue and, eventually, into other parts of the body. Most cancers that start in lung, known as primary...
, sued Philip Morris USA
Philip Morris USA
Philip Morris USA is the United States tobacco division of Altria Group, Inc. Philip Morris USA brands include Marlboro, Virginia Slims, Benson and Hedges, Merit, Parliament, Alpine, Basic, Cambridge, Bucks, Dave's, Chesterfield, Collector's Choice, Commander, English Ovals, Lark, L&M, Players and...
, a cigarette manufacture
Tobacco industry
The tobacco industry comprises those persons and companies engaged in the growth, preparation for sale, shipment, advertisement, and distribution of tobacco and tobacco-related products. It is a global industry; tobacco can grow in any warm, moist environment, which means it can be farmed on all...
r, for fraud
Fraud
In criminal law, a fraud is an intentional deception made for personal gain or to damage another individual; the related adjective is fraudulent. The specific legal definition varies by legal jurisdiction. Fraud is a crime, and also a civil law violation...
based on Philip Morris advertisements and sponsored studies that made cigarettes seem less dangerous than they actually were. At trial
Trial
A trial is, in the most general sense, a test, usually a test to see whether something does or does not meet a given standard.It may refer to:*Trial , the presentation of information in a formal setting, usually a court...
, the jury found for Williams and awarded her $821,485.50 in compensatory damages and $79.5 million in punitive damages. The trial court found that the compensatory damages exceeded the state cap and the punitive damages were "grossly excessive". It reduced the respective amounts to $521,485.50 and $32 million.
On appeal, the Oregon Court of Appeals
Oregon Court of Appeals
The Oregon Court of Appeals is the state intermediate appellate court in the U.S. state of Oregon. Part of the Oregon Judicial Department, it has ten judges and is located in Salem...
reversed and reinstated the $79.5 million judgment. Following the "guideposts" established in BMW of North America, Inc. v. Gore
BMW of North America, Inc. v. Gore
BMW of North America, Inc. v. Gore, 517 U.S. 559 , was a United States Supreme Court case limiting punitive damages under the Due Process Clause of the 14th Amendment.-Facts:...
, the Court of Appeals examined whether the punitive damages were appropriate based on (1) the degree of reprehensibility of the conduct, (2) the disparity between the actual harm and the punitive damages, and (3) the difference between the punitive damages and civil penalties allowed in similar cases. While determining the reprehensibility of Philip Morris's actions, the court considered the length of the misinformation campaign and the number of people it had reached, concluding that its actions were so reprehensible that they justified punitive damages 97 times greater than the actual damages. The Oregon Supreme Court
Oregon Supreme Court
The Oregon Supreme Court is the highest state court in the U.S. state of Oregon. The only court that may reverse or modify a decision of the Oregon Supreme Court is the Supreme Court of the United States. The OSC holds court at the Oregon Supreme Court Building in Salem, Oregon, near the capitol...
denied review.
The Supreme Court of the United States then granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
, vacated
Vacated judgment
A vacated judgment makes a previous legal judgment legally void. A vacated judgment is usually the result of the judgment of an appellate court which overturns, reverses, or sets aside the judgment of a lower court....
the Court of Appeals' judgment, and remanded the case to the Court of Appeals for that court to reconsider the amount of the punitive damages award in light of State Farm v. Campbell. The Court of Appeals again reinstated the $79.5 million judgment. On appeal, the Supreme Court of Oregon affirmed, also holding that the courts can consider evidence of similar conduct to other people in Oregon–even those not party to the law suit–when awarding punitive damages.
The counsel for petitioner Philip Morris USA was Andrew L. Frey and Mayer Brown. The counsel for respondent Williams was Robert S. Peck; Center for Constitutional Litigation, P.C.
See also
External links
- Supreme Court opinion on FindLawFindLawFindLaw is a business of Thomson Reuters that provides online legal information and online marketing services for law firms. FindLaw was created by Stacy Stern, Martin Roscheisen and Tim Stanley in 1995, and was acquired by Thomson West in 2001....