In State Farm Mutual Automobile Ins. Co. v. Campbell, 538 U.S. 408 (2003), the Court once again applied the guideposts it set down in BMW of North America, Inc. v. Gore to vacate a $ 145 million punitive damage award against a corporate defendant. (State Farm, 538 U.S. at 429.) The injury in question was emotional distress caused by the defendant insurer's unwillingness to settle an automobile accident claim. The jury awarded plaintiffs $ 1 million in compensatory damages for their injuries. In its determination, the Supreme Court found that the award ran afoul of each of the Gore guideposts. With regard to the first guidepost, the Court found that, while defendant's conduct toward the plaintiffs was not worthy of praise, it was not so reprehensible as to warrant the $ 145 million award. (Id. at 419-420.) The Court also noted that most of the evidence introduced concerned defendant's nationwide practices and policies, and had little relation to the tortious conduct directed toward defendants. (Id. at 420-425.) With regard to the second guidepost, the Court found that there is a presumption against a 145 to 1 punitive- to-actual damages ratio. (Id. at 426.) It further noted that compensatory damages in emotional distress cases frequently include punitive elements already, so that the punitive-to-actual ratio may be even higher. (Id.) As to the third guidepost, the Court found that the only relevant state civil sanction was a $ 10,000 fine for the act of fraud. (Id. at 428.) In its analysis, the Court noted that "[t]he wealth of a defendant cannot justify an otherwise unconstitutional punitive damages award." (Id. at 427 .)