In Gamble v. Stevenson, 305 S.C. 104, 406 S.E.2d 350 (1991) the South Carolina Supreme Court developed an eight factor post-verdict review which trial courts are required to conduct to determine if a punitive damages award comports with due process.
The Gamble factors are:
(1) defendant's degree of culpability;
(2) duration of the conduct;
(3) defendant's awareness or concealment;
(4) the existence of similar past conduct;
(5) likelihood the award will deter the defendant or others from like conduct;
(6) whether the award is reasonably related to the harm likely to result from such conduct;
(7) defendant's ability to pay; and finally;
(8) as noted in Haslip, "other factors" deemed appropriate. (Gamble, 305 S.C. at 111-12, 406 S.E.2d at 354.)
Under Gamble, the trial court is not required to make findings of fact for each factor to uphold a punitive damage award. McGee v. Bruce Hosp. Sys., 321 S.C. 340, 468 S.E.2d 633 (1996).