Exxon Shipping Co. v. Baker

In Exxon Shipping Co. v. Baker (2008) 554 U.S. 471, the United States Supreme Court observed that there are "several studies . . . showing the median ratio of punitive to compensatory verdicts, reflecting what juries and judges have considered reasonable across many hundreds of punitive awards." (Id., 128 S.Ct. at p. 2632.) The "studies cover cases of the most as well as the least blameworthy conduct triggering punitive liability, from malice and avarice, down to recklessness, and even gross negligence in some jurisdictions. The data put the median ratio for the entire gamut of circumstances at less than 1:1, . . . meaning that the compensatory award exceeds the punitive award in most cases. In a well-functioning system, we would expect that awards at the median or lower would roughly express jurors' sense of reasonable penalties in cases with no earmarks of exceptional blameworthiness within the punishable spectrum . . . ." (Id., at p. 2633.) The Supreme Court noted that it "has long held that 'punitive damages by definition are not intended to compensate the injured party, but rather to punish the tortfeasor . . . and to deter him and others from similar extreme conduct.' Citation." (Exxon Shipping Co. v. Baker, supra, 128 S.Ct. at p. 2633.) The trial court here could have reasonably concluded that punitive damages of $ 1.2 million, together with compensatory damages in the same amount, were sufficient to punish appellant and "'deter it and others from similar extreme conduct.'" (Ibid.)