Honda Motor Co. v. Oberg
Supreme Court of the United States
April 20, 1994, Argued ; June 24, 1994, Decided
[*418] [***341] [**2334] JUSTICE STEVENS delivered the opinion of the Court.
An amendment to the Oregon Constitution 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 question presented is whether that prohibition is consistent with the Due Process Clause of the Fourteenth Amendment. We hold that it is not.
Petitioner Honda Motor Co., Ltd., manufactured and sold the three-wheeled all-terrain vehicle that overturned while respondent was driving it, causing him severe and permanent injuries. Respondent brought suit alleging that petitioner knew or should have known that the vehicle had an inherently and unreasonably dangerous design. The jury found petitioner liable and awarded respondent $ 919,390.39 in compensatory damages and punitive damages of $ 5 million. [****8] The compensatory damages, however, were reduced by 20% to $ 735,512.31, because respondent's own negligence contributed to the accident. On appeal, relying on our then-recent decision in Pacific Mut. Life Ins. Co. v. Haslip, 499 U.S. 1, 113 L. Ed. 2d 1, 111 S. Ct. 1032 (1991), petitioner argued that the award of punitive damages violated the Due Process Clause of the Fourteenth Amendment, because the punitive damages were excessive and because Oregon courts lacked the power to correct excessive verdicts.
The Oregon Court of Appeals affirmed, as did the Oregon Supreme Court. The latter court relied heavily on the fact that the Oregon statute governing the award of punitive damages in product liability actions and the jury instructions in this case contain substantive criteria that provide [*419] at least as much guidance to the factfinders as the Alabama statute and jury instructions that we upheld in Haslip. The Oregon Supreme Court also noted that Oregon law provides an additional protection by requiring the plaintiff to prove entitlement to punitive damages by clear and convincing evidence rather than a mere preponderance. [***342] Recognizing that other state [****9] courts had interpreted Haslip as including a "clear . . . constitutional mandate for meaningful judicial scrutiny of punitive damage awards," Adams v. Murakami, 54 Cal. 3d 105, 118, 813 P.2d 1348, 1356, 284 Cal. Rptr. 318 (1991); see also Alexander & Alexander, Inc. v. B. Dixon Evander & Assocs., Inc., 88 Md. App. 672, 596 A.2d 687 (1991), the court nevertheless declined to "interpret Haslip to hold that an award of punitive damages, to comport with the requirements of the Due Process Clause, always must be subject to a form of post-verdict or appellate review that includes the possibility of remittitur." 316 Ore. 263, 284, 851 P.2d 1084, 1096 (1993). It also noted that trial and appellate courts were "not entirely powerless" because a judgment may be vacated if "there is no evidence to support the jury's decision," and because "appellate review is available to test the sufficiency of the jury instructions." Id., at 285, 851 P.2d at 1096-1097.
[****10] [*420] We granted certiorari, 510 U.S. 1068 (1994), to consider whether Oregon's limited judicial [**2335] review of the size of punitive damages awards is consistent with our decision in Haslip.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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512 U.S. 415 *; 114 S. Ct. 2331 **; 129 L. Ed. 2d 336 ***; 1994 U.S. LEXIS 4825 ****; 62 U.S.L.W. 4627; CCH Prod. Liab. Rep. P13,895; 94 Cal. Daily Op. Service 4761; 94 Daily Journal DAR 8844; 8 Fla. L. Weekly Fed. S 341
HONDA MOTOR CO., LTD., ET AL., PETITIONERS v. KARL L. OBERG
Prior History: [****1] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF OREGON.
Disposition: 316 Ore. 263, 851 P. 2d 1084, reversed and remanded.
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Civil Procedure, Remedies, Damages, Punitive Damages, Torts, Punitive Damages, Measurement of Damages, Constitutional Requirements, Types of Damages, General Overview, Jury Trials, Jury Instructions, Judicial Review, Administrative Law, Judicial Review, Standards of Review, Judgments, Relief From Judgments, Trials, Right to Jury Trial, Constitutional Law, Bill of Rights, Fundamental Rights, Eminent Domain & Takings, Procedural Due Process