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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

Other Sections in This Document (232)

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In Wallace v. DTG Operations, Inc., 563 F.3d 357, 359, 362 (8th Cir.2009), a retaliation case, our court found a punitive damages award, which was “approximately sixteen times greater than all of the actual damages combined” was excessive. Citing Campbell, we reasoned, because the jury’s award of $30,000 in actual damages was not a nominal amount, “a single-digit multiple should be the outer limit on [the punitive damages] award.” Id. at 362. We observed, the Supreme Court found a punitive damages award “ ‘more than 4 times the amount of compensatory damages ... close to the line’ ” of constitutionality. Id. at 363 (quoting Pac. Mut. Life Ins. Co. v. Haslip, 499 U.S. 1, 23-4, 111 S.Ct. 1032, 113 L.Ed.2d 1 (1991)). Based on the Court’s guidance in Campbell and Haslip, we found “a four-to-one ratio” was an appropriate ratio. Id.