Tuesday, July 30, 2019

Federal Western District Court of Pennsylvania Finds Punitive Damages Awarded by Jury at a 100:1 Ratio to Be Unconstitutionally Excessive



In the case of Hyman v. Devlin, No. 3:17-89 (W.D. Pa. June 10, 2019 Gibson, J.), the court ruled that a 100:1 ratio of punitive damages to compensatory damages in a jury award was unconstitutional.   

This case arose out of a Pennsylvania State Police Trooper’s intervention in the civil repossession of an automobile. The case proceeded to a jury trial and the jury returned the verdict in the Plaintiff’s favor, awarding her $5,000.00 in compensatory damages and $500,000.00 in punitive damages.

Following the verdict, the Defendant filed a Post-Trial Motion under Rule 59(e) of the Federal Rules of Civil Procedure arguing, in part, that the jury’s punitive damages award was unconstitutionally excessive.   

In this case, the court ruled that, based upon a compensatory damages award of $5,000.00, the maximum allowable punitive damages award would be $30,000.00.

This decision is also notable for its review of the law surrounding Motions for Reconsideration in federal courts.

Anyone wishing to review a copy of this decision may click this LINK.


I send thanks to Attorney James M. Beck of the Philadelphia office of the Reed Smith law firm for bringing this case to my attention.   Please check out Attorney Beck’s excellent Drug and Device Law blog HERE.




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