Pacific Mutual Life Ins. Co. v. Haslip
United States Supreme Court
499 U.S. 1 (1991)
Pacific Mutual's (defendant's) insurance agent misappropriated premiums paid by Haslip and others (plaintiffs), leaving Haslip without coverage and facing a medical debt judgment; at trial, the jury was instructed that punitive damages were discretionary and should reflect the character of the wrong and the need for deterrence, and it awarded punitive damages, which the Alabama Supreme Court affirmed after applying detailed reasonableness factors. Pacific Mutual sought Supreme Court review, arguing the jury's broad discretion violated due process.
Whether a jury's award of punitive damages violates due process where the jury is informed such damages are discretionary, guided to consider the nature and purpose of the damages and the wrongdoing's extent, and the award receives substantive appellate review.