Thursday, November 14, 2013

BMW of North America, Inc. v. Gore case brief

BMW of North America, Inc. v. Gore case brief summary
517 U.S. 559 (1996)


CASE SYNOPSIS
Petitioner automobile distributor appealed a decision of the Supreme Court of Alabama, which affirmed a finding in favor of respondent auto owner on petitioner's post-trial motion to set aside a punitive damages award in an action alleging suppression of a material fact.

CASE FACTS
Respondent discovered that his new car had been repainted. He brought suit against petitioner distributor alleging that its failure to disclose the repair constituted suppression of a material fact. Evidence was introduced at trial that petitioner had a policy of nondisclosure where pre-delivery repairs amounted to less than 3 percent of the retail price of the car. The jury awarded actual damages of $ 4,000 and punitive damages of $ 4,000,000. Petitioner's motion to set aside the punitive damages award was denied by both the trial court and the appellate court. However, the appellate court reduced the award to $ 2,000,000 because it was inaccurately calculated.

DISCUSSION
  • The United States Supreme Court granted certiorari. 
  • It reversed and remanded the case. 
  • It held that petitioner's conduct was not particularly reprehensible because it only caused minor economic harm and the 500 to 1 ratio of punitive damages to compensatory damages was not reasonable.
CONCLUSION
The denial of a motion to set aside the punitive damages award was reversed where the Court held that petitioner distributor's conduct was not particularly reprehensible because it only caused minor economic harm and a 500 to 1 ratio of punitive damages to compensatory damages was not reasonable.

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