Devlin v. Kearny Mesa AMC/Jeep/Renault, Inc.

1984

Court: California Court of Appeals

Facts: Using every nasty sales tactic in the book, a car dealer pressures an unhealthy elderly couple into buying a car. They also falsely represented that the car had less mileage than it actually did. And that it had not been owned. Lo, it needs repairs, and some documentation of prior ownership and mileage turns up.

Posture: The dealer appeals for a second time from judgment for the plaintiffs.

Issue: Are the punitive damages excessive?

Holding: No. Affirmed.

Rule: There is no precise ratio for punitive damages. Instead, the court must consider the nature of the bad act, the amount of compensatory damages, and the wealth of the defendant. These are meant to be punitive, after all.

Reasoning: This merits a large award, and it appears as though the jury weighed these factors. It's not excessive as a matter of law.

Dicta: