Thursday, November 14, 2013

Philip Morris U.S.A. v. Williams case brief

Philip Morris U.S.A. v. Williams case brief summary
127 S. Ct. 1057 (2007)

Respondent representative of a decedent's estate sued petitioner cigarette manufacturer, alleging that the deceit of the manufacturer in minimizing the dangers of smoking cigarettes contributed to the decedent's death from smoking. Upon the grant of a writ of certiorari, the manufacturer challenged the judgment of the Oregon Supreme Court which upheld a punitive damages award against the manufacturer.

The manufacturer contended that the jury was impermissibly permitted to calculate punitive damages based on harm to parties who were not parties to the litigation. The representative asserted that the jury was entitled to consider harm to non-parties in assessing the reprehensibility of the manufacturer's conduct for purposes of punitive damages.


  • The U.S. Supreme Court held that, if the punitive damages award was based in part on the jury's desire to punish the manufacturer for harming non-parties, such an award amounted to a taking of property from the manufacturer without due process. 
  • While it was permissible to consider non-party harm in determining reprehensibility, the punitive damages award to punish the manufacturer for injury inflicted on strangers to the litigation, without an opportunity to defend the charge, violated due process. 
  • Thus, procedures were required to inform the jury that, while harm to non-parties was relevant to reprehensibility, punitive damages could not be awarded to punish the manufacturer for such harm.
The judgment upholding the punitive damages award was vacated, and the case was remanded for reconsideration of the award.

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