CALIFORNIA COURT OF APPEAL LIMITS PUNITIVE DAMAGES UNDER STATE FARM v. CAMPBELL
In this sexual harassment case (Gober v. RGC, Case No. D040473, decided March 1, 2006), the Court of Appeal in San Diego held that a jury’s $20 million punitive damage award was constitutionally excessive where the total of compensatory damages awarded to all of the plaintiff emplyees was only $250,000, a ratio of 80 to 1. The Court described the employer’s conduct as, at most, only modestly reprehensible, and decided that, under the principles articulated by the U.S. Supreme Court in State Farm v. Campbell, the constitutional maximum amount of punitive damages was six times the compensatory damages awarded to each employee.
To view the Court
of Appeal's opinion, click
here.
Horvitz & Levy LLP represented the defendant on appeal. For more
information, call Daniel Gonzalez at (818) 995-0800 or send an e-mail
to
him at dgonzalez@horvitzlevy.com.
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