4th highest punitive damages verdict of 2011 is headed for a new trial

As far as we can tell, the $200 million punitive damages award against Allergan in Virginia was the 4th biggest punitive damages award of 2011.  The Orange County Register reports that Allergan has won a new trial in that case.  According to the article, Judge Robert E. Payne of the Eastern District of  Virginia ruled that the jury should have been told that Allergan could not add a so-called “black box” warning to its Botox package inserts wtihout prior approval from the FDA.