Honda Motor Co. v. Oberg

1994

Venue: SCOTUS

Facts: OR amended its constitution to prohibit judicial review of the size of punitive damage awards by juries. Oberg got hurt badly while driving a Honda ATV, and got a major award.

Posture: Award for Oberg at trial, reduced somewhat due to contributory negligence. Appeal by Honda.

Issue: Is judicial review necessary in order to prevent punitive damage awards from being so grossly excessive that they violate due process?

Holding: Yes. That amendment violates 14A's due process clause.

Rule: Punitive damage awards can violate due process, and we can't have that.

Reasoning: We need procedural safeguards when there's a risk of things running amok. Juries have the potential to run amok. We can review the legality of their findings, but even though the findings are correct, the amount of the award can still be flagrantly crazy. We require, therefore, the capability to limit amounts.

Dicta: Ginsburg (dissenting): the fact that clear-and-convincing evidence of wanton conduct is required for punitive damages is a sufficient guard to protect non-egregious offenders.