Henley v. Philip Morris, Inc.

California Court of Appeal

9 Cal. Rptr. 3d 29 (Cal. Ct. App. 2004)

The Due Process Clause of the Fourteenth Amendment prohibits the imposition of arbitrary or grossly excessive punishments on a tortfeasor.

Relevant Facts

When she was 15 years hold, Henley (the plaintiff) began smoking Marlboro cigarettes, which were manufactured by Philip Morris, Inc. (the defendant). The plaintiff became addicted and smoked cigarettes for 35 years until she was diagnosed with lung cancer. The plaintiff brought a products-liability suit against the defendant, claiming that its cigarettes were defective. At trial, the plaintiff presented evidence that the defendant intentionally deceived the public as to the dangerousness of cigarettes for several years, targeted its advertisements at teenagers, and also failed to warn of the known dangers of cigarettes, including their addictiveness. The jury awarded the plaintiff $1.5 million in compensatory damages and $50 million in punitive damages. On the defendant’s motion, the trial court gave the plaintiff a choice between (1) consenting to a reduction in punitive damages to $25 million or (2) to have a new trial solely on the issue of punitive damages. The plaintiff chose to consent to the reduction, and the trial court entered judgment in favor of the plaintiff. The defendant appealed.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 23, 2020

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Procedural History

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Citations

9 Cal. Rptr. 3d 29 (Cal. Ct. App. 2004)