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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Quigley v. Winter, 598 F.3d 938 (2010)

Citation
Quigley v. Winter, 598 F.3d 938 (2010)
Parent Document
Quigley v. Winter, 598 F.3d 938 (2010)
Effective Date
2010-03-16

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Yet, later, in Campbell, the Court declared, “Our jurisprudence and the principles it has now established demonstrate *955... few awards exceeding a single-digit ratio between punitive and compensatory damages, to a significant degree, will satisfy due process.” Campbell, 538 U.S. at 425, 123 S.Ct. 1513. The Court continued, “Single-digit multipliers are more likely to comport with due process, while still achieving the State’s goals of deterrence and retribution.” Id. The Court reiterated there was “a long legislative history, dating back over 700 years and going forward to today, providing for sanctions of double, treble, or quadruple damages to deter and punish.” Id. (citing Gore, 517 U.S. at 581 n. 33, 116 S.Ct. 1589). The district court then declared, “While these ratios are not binding, they are instructive.” Id.