BMW of North America, Inc. v. Gore
Supreme Court of the United States Official seal of the Supreme Court of the United States File links The following pages link to this file: Marbury v. ...
Argued Decided May 20, 1996
Full case name: BMW of North America, Inc. v. Dr. Ira Gore, Jr. Citations: 517 U.S. 559 Prior history: Award of punitive damages upheld in Alabama Supreme Court Subsequent history:
Holding
Excessive punitive damages awards violate procedural due process.
Court membership
Chief Justice: William Rehnquist Associate Justices: John Paul Stevens, Sandra Day O'Connor, Anthony Kennedy, Antonin Scalia, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer
Case opinions
Majority by: Stevens Joined by: Kennedy, O'Connor, Souter, Breyer Concurrance by: Breyer Joined by: O'Connor, Souter Dissent by: Scalia Joined by: Thomas Dissent by: Ginsburg Joined by: Rehnquist
Laws applied
U.S. Const. amend. XIV

BMW of North America, Inc. v. Gore, 517 U.S. 559 (1996), was a United States Supreme Court case limiting punitive damages under the Due Process Clause of the 14th Amendment. Court citation is a standard system used in common law countries such as the United States, United Kingdom, Canada, and Australia to uniquely identify the location of past court cases in special series of books called reporters. ... 1996 is a leap year starting on Monday of the Gregorian calendar, and was designated the International Year for the Eradication of Poverty. ... The Supreme Court Building, Washington, D.C. The Supreme Court Building, Washington, D.C., (large image) The Supreme Court of the United States, located in Washington, D.C., is the highest court (see supreme court) in the United States; that is, it has ultimate judicial authority within the United States... Punitive damages are damages awarded to a successful plaintiff in a civil action, over and above the amount of compensatory damages, to: punish the conduct of the civil defendant; deter the civil defendant from committing the invidious act again; and deter others from doing the same thing. ... Due process of law is a legal concept that ensures the government will respect all of a persons legal rights instead of just some or most of those legal rights, when the government deprives a person of life, liberty, or property. ... Amendment XIV (the Fourteenth Amendment) of the United States Constitution is one of the post-Civil War amendments and includes the due process and equal protection clauses (Section 1). ...

Facts

The plaintiff, Dr. Ira Gore, bought a new BMW, and later discovered that the paint had been damaged and repaired before he bought it. Defendant BMW revealed that their policy was to sell damaged cars as new if the damage could be fixed for less than 3 percent of the car. Dr. Gore sued, and an Alabama jury awarded $4,000 in compensatory damages (lost value of the car) and $4 million in punitive damages, which was later reduced to $2 million by the Alabama Supreme Court. A plaintiff, also known as a claimant, or a complainant is the party who initiates a lawsuit (also known as an action) before a court. ... The BMW logo is a circle (known as a roundel) divided into quadrants of alternating white and light blue color. ... A defendant is any party who is required to answer the complaint of a plaintiff in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute. ... State nickname: Camellia State, The Heart of Dixie¹, Yellowhammer State Other U.S. States Capital Montgomery Largest city Birmingham Governor Bob Riley (R) Official languages English Area 84,360 mi²/135,765 km² (30th)  - Land 81,664 mi²/131,426 km²  - Water 2,696 mi²/4,338 km² (3. ... Punitive damages are damages awarded to a successful plaintiff in a civil action, over and above the amount of compensatory damages, to: punish the conduct of the civil defendant; deter the civil defendant from committing the invidious act again; and deter others from doing the same thing. ...

Issue

Do excessively high punitive damages violate the Due Process clause of the Constitution?

Opinion of the Court

The Court, in an opinion by Justice Stevens, found that the excessively high punitive damages in this case violate the Due Process clause. For punitive damages to stand, the damages must be reasonably necessary to vindicate the State’s legitimate interest in punishment and deterrence. Punitive damages may not be "grossly excessive" - if they are they violate substantive due process. Justice John Paul Stevens Justice John Paul Stevens (born April 20, 1920) is an American jurist who has been a U.S. Supreme Court Associate Justice since 1975; he is the oldest justice on the court. ...

The Supreme Court applied three factors in making this determination:

1. The degree of reprehensibility of the defendant’s conduct;
2. the ratio to the compensatory damages awarded (actual or potential harm inflicted on the plaintiff); and
3. Comparison of the punitive damages award and civil or criminal penalties that could be imposed for comparable misconduct.

Using these factors, the Court found that BMW’s conduct was not particularly reprehensible (no reckless disregard for health or safety, nor even evidence of bad faith). The ratio of actual or potential damages to punitive damages was suspiciously high. Finally, the criminal sanctions available for similar conduct were limited to $2,000, making the $2 million assessment the equivalent of a severe criminal penalty)

The Court noted, however, that these three factors can be over-ridden if it is "necessary to deter future conduct."

Dissenting opinions were written by Justice Scalia and Justice Ginsburg both contending that the Constitution was not implicated here, raising principles of federalism. Justice Antonin Scalia Justice Antonin Scalia (born March 11, 1936) has been a US Supreme Court Associate Justice since 1986. ... Ruth Joan Bader Ginsburg (born March 15, 1933) is a United States jurist. ...

External link

• 517 U.S. 559 (Text of the opinion on Findlaw.com)