Bankers Life & Casualty Co. v. Crenshaw
United States Supreme Court
486 U.S. 71 (1988)
Lloyd Crenshaw (plaintiff) sued his insurer, Bankers Life & Casualty (defendant), for bad-faith refusal to pay a $20,000 disability claim and won $20,000 in actual and $1.6 million in punitive damages at trial, a verdict the Mississippi Supreme Court affirmed. Only in its petition for rehearing did Bankers vaguely assert the punitive award "constitutes excessive fine" and violates "constitutional principles," without clearly identifying a federal constitutional provision; the Mississippi Supreme Court denied rehearing, and Bankers appealed to the U.S. Supreme Court.
Whether a federal constitutional challenge to a state-court punitive damages award may be heard on appeal when it was not clearly raised in the proceedings below.