In Pacific Mutual Life Insurance Co. v. Haslip (1990) 499 U.S. 1, the United States Supreme Court put its lens to Alabama's punitive damages system. Upholding that system, the court noted with approval that in Alabama: (1) the court instructs the jury on the nature and purpose of punitive damages and explains that their imposition is not compulsory; (2) the trial court scrutinizes punitive awards on a posttrial challenge to excessiveness of damages according to a number of factors, noting on the record the reasons for upholding or interfering with the verdict; (3) the state Supreme Court measures the punitive damages verdict against established standards to guard against excessiveness. (Haslip, supra, 499 U.S. at pp. 19-22.) The Haslip court expressed some concern with state schemes operating under a similar standard of review. (Haslip, supra, 499 U.S. at p. 21, fn. 10.) By way of contrast, it was comfortable that Alabama's review scheme ensures that a jury's award does not exceed an amount that will accomplish society's twin goals of punishment and deterrence. (Id. at p. 21.)