“The Court rightly held that the jury’s $16 million punitive award bore no reasonable relationship to its $150,000 compensatory award for the injury suffered.”
—Cory Andrews, WLF General Counsel & Vice President of Litigation
(Washington, DC)—The Florida Supreme Court today provided much-needed guidance to lower Florida courts on how to evaluate punitive damages awards in wrongful death actions. In affirming Florida’s Fifth District Court of Appeal, Florida’s high court held that the trial court’s $16 million punitive damages award bore no reasonable relation to the amount of damages proved and the injury suffered, as required by Florida law. The decision was a victory for Washington Legal Foundation (WLF), which filed an amicus brief urging affirmance.
The case arose from a wrongful death action against R.J. Reynolds Tobacco Company. After hearing all the evidence, the jury rejected the plaintiff’s claims for fraudulent concealment, conspiracy, and negligence. Awarding the plaintiff $150,000 on her design-defect claim, the jury then awarded her a staggering $16 million in punitive damages. That award produced an eye-popping 106:1 punitive-to-compensatory ratio. On appeal, Florida’s Fifth District Court of Appeal reversed that outsized award.
In affirming that decision, the Florida Supreme Court emphasized that although a Florida trial court has broad discretion in ruling on a motion for remittitur of a damages award, that discretion is constrained by statutory criteria that must be considered in determining whether the award is excessive. The Florida statutes require a punitive damages award in a wrongful death action to bear a reasonable relation to the amount of damages proved and the injury suffered by the statutory beneficiaries. The trial court’s award flunked that test. Because the appeal could be resolved on a statutory basis alone, the court declined to further analyze the issue as a matter of Florida or federal constitutional law.