In State Farm Mut. Automobile Ins. Co. v. Campbell (2003) 538 U.S. 408, the plaintiffs brought a bad faith action in Utah state court against their insurance carrier, State Farm, and obtained a $ 145 million punitive damages award. (Id. at pp. 412-413.) The plaintiffs introduced evidence that State Farm's conduct was a result of a national scheme to meet corporate fiscal goals, as well as evidence of State Farm business practices in other states that bore no relation to the type of insurance claim underlying the plaintiffs' bad faith action. (Id. at p. 415.) Much of State Farm's out-of-state conduct was lawful where it occurred. (Id. at p. 422.) Nevertheless, in affirming the punitive damages award, the Utah Supreme Court explicitly indicated that "State Farm was being condemned for its nationwide policies rather than for the conduct directed toward the plaintiffs." (Id. at p. 420.) The Supreme Court held that the punitive damages award violated State Farm's right to due process. The court reasoned: "A defendant should be punished for the conduct that harmed the plaintiff, not for being an unsavory individual or business. Due process does not permit courts, in the calculation of punitive damages, to adjudicate the merits of other parties' hypothetical claims against a defendant . . . ." (State Farm, supra, 538 U.S. at p. 423.) The high court further stated that in reviewing punitive damages, the courts must consider, among other factors, the degree of reprehensibility of the defendant's misconduct. (State Farm, supra, 538 U.S. at p. 418.) With respect to the reprehensibility of the defendant's conduct, the court stated that "lawful out-of-state conduct may be probative when it demonstrates the deliberateness and culpability of the defendant's action in the State where it is tortious, but that conduct must have a nexus to the specific harm suffered by the plaintiff." (Id. at p. 422.)