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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 (1991)). Based on the Court’s guidance in Campbell and
Haslip, we found “a four-to-one ratio” was an appropriate ratio. Id.