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Oberg v. Honda Motor Co. - 316 Or. 263, 851 P.2d 1084 (1993)

Rule:

In cases involving potential awards of punitive damages in Oregon, the finder of fact must determine what punitive damages, if any, to award based on the proper premise of deterring future similar misconduct by the defendant or others. To this end, a number of factors may be relevant, including the seriousness of the hazard to the public, the attitude and conduct of the wrongdoer upon learning of the hazard, the number and position of employees involved in causing or covering up the misconduct, the duration of the misconduct or its cover-up, the financial condition of the wrongdoer, and prior and potential punishment from similarly situated plaintiffs or other sources.

Facts:

Plaintiff Karl L. Oberg attempted to drive an all-terrain vehicle (ATV) manufactured and sold by defendant Honda Motor Co., Ltd. up a steep embankment. It overturned backward and injured him. Plaintiff then brought the current product liability action against defendants alleging that it was negligent in manufacturing, distributing, and selling the ATV, because they knew or should have known that it had inherently dangerous design that rendered it unreasonably dangerous to users. A jury returned a verdict in favor of plaintiff, awarding both general and punitive damages. Defendants appealed. They argued, among other things, that the trial court erred in admitting in evidence excerpts of various documents generated by the Consumer Product Safety Commission (CPSC), relating to the safety of ATVs. Defendants also argued that the trial court erred in denying their motion for a new trial on the basis of the discovery of new eyewitnesses to plaintiff's accident. Finally, they argued that the award of punitive damages was excessive and, therefore, violated their rights under Article I, section 16, of the Oregon Constitution and the Due Process Clause of the Fourteenth Amendment to the Constitution of the United States. The state appellate court affirmed. Defendants sought review.

Issue:

Did the jury's award of punitive damages to the injured plaintiff in this product liability case violate the Due Process Clause of the Fourteenth Amendment as "excessive"?

Answer:

No

Conclusion:

The Supreme Court of Oregon affirmed the judgment in favor of plaintiff. According to the Court, the admission of Consumer Products Safety Commission documents was not error. The Court held that Consumer Products Safety Commission documents were relevant to issues at trial and were not hearsay because they were offered to prove notice of the dangerousness of ATVs, not the truth of the matters asserted therein. The Court further ruled that the provision against excessive fines in Or. Const. art. I, § 16 applied only to criminal cases. Application of objective criteria in considering punitive damages ensured that sufficiently definite and meaningful constraints were imposed on the finder of fact. The criteria established by Or. Rev. Stat. § 30.925 were detailed and objective, and were thus constitutionally sufficient. The jury was instructed properly about the substantive criteria to be applied, and there was evidence to support its determination. The punitive damages award thus did not violate the Due Process Clause of the Fourteenth Amendment.

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