On November 30, 2011, the California Supreme Court declined to review a state appeals court decision that upheld an excessive $13.8 million punitive damages award—more than sixteen times the compensatory damages award—to a lifetime smoker who died of lung cancer after smoking for over 45 years. The decision was a setback for WLF, which filed a brief in the case urging the court to review, and ultimately overturn, the punitive damages award. In its brief, WLF argued that the appeals court improperly relied on the corporate defendant’s financial condition in deciding to overcome the U.S. Supreme Court’s presumption that a punitive damages award exceeding a single-digit ratio to compensatory damages violates the Due Process Clause of the Fourteenth Amendment.