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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Mignone v. Mo. Dep't of Corr., 546 S.W.3d 23 (2018)

Citation
Mignone v. Mo. Dep't of Corr., 546 S.W.3d 23 (2018)
Parent Document
Mignone v. Mo. Dep't of Corr., 546 S.W.3d 23 (2018)
Jurisdiction
Missouri (state)
Effective Date
2018-02-06

Other Sections in This Document (127)

Full Text

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With regard to the second Gore guidepost, [the Supreme Court of the United States] has been reluctant to identify concrete constitutional limits on the ratio between harm, or potential harm, to the plaintiff and the punitive damages award; but, in practice, few awards exceeding a single-digit ratio between punitive and compensatory damages will satisfy due process. Single-digit multipliers are more likely to comport with due process, while still achieving the State's deterrence and retribution goals.... Because there are no rigid benchmarks, ratios greater than those that this Court *45has previously upheld may comport with due process where a particularly egregious act has resulted in only a small amount of economic damages, but when compensatory damages are substantial, then an even lesser ratio can reach the outermost limit of the due process guarantee.