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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 . . . 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. 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). The district court then declared, “While these
ratios are not binding, they are instructive.” Id.