Boise Dodge, Inc. v. Clark

Clark (defendant) bought a car from Boise Dodge, Inc. (plaintiff) after a salesman described it as 'new' with 165 miles showing; in fact it was a demonstrator whose odometer the general manager knew had been rolled back from 7,000 miles. Clark traded in a car, wrote a $500 check, and paid cash, then stopped payment on discovering the truth. Boise Dodge sued on the checks; Clark counterclaimed for fraud and punitive damages. The jury awarded Boise Dodge $2,062, awarded Clark actual damages for the misrepresentation, and added $12,500 in punitive damages, which the appellate court affirmed.

Whether the amount of punitive damages awarded must bear a reasonable relation to the amount of actual damages the party suffered.