Philip Morris USA v. Williams, 549 U.S. 346 (2007)
Primary Holding
A jury may not base a punitive damages award on its desire to punish a defendant for harm caused to individuals not before the court, as doing so would violate the Due Process Clause by constituting a taking of property without due process.
In the case of Philip Morris USA v. Williams, the Supreme Court ruled that juries cannot punish companies for harming people who are not part of the case being tried. This is important because it protects companies from being unfairly punished for actions that affected individuals who are not represented in court, ensuring that any penalties are based only on the specific harm done to the people involved in the lawsuit. This case is relevant if you are involved in a legal dispute and are concerned about how damages might be awarded; it reinforces that any penalties should be fair and directly related to the parties in the case.
AI-generated plain-language summary to help you understand this case
The widow of Jesse Williams sued Philip Morris USA, which had made the Marlboro cigarettes that her husband had smoked at the rate of three packs per day for most of his life until he died of lung cancer. This wrongful death action was based on the assertion that Philip Morris had deliberately misinformed consumers about the health risks of smoking. Williams prevailed at trial and received about $800,000 in compensatory damages as well as $79.5 million in punitive damages. After the trial judge reduced the punitive damages award to $32 million because it was found to be excessive, the higher state courts reinstated the original award. They found that the conduct of Philip Morris merited imposing a larger damages award because it was thoroughly egregious. Philip Morris argued that the award exceeded constitutional restrictions on the scale of punitive damages. It also pointed out that the jury had based the award in part on harm to other smokers, who had not been involved as parties in the case.
Whether the Constitution’s Due Process Clause permits a jury to base a punitive damages award in part upon its desire to punish the defendant for harming persons who are not before the court.
The judgment is reversed.
A party not involved in the lawsuit cannot be punished by the outcome of the lawsuit because it lacked the opportunity to be heard. Otherwise, a punitive damages award would be too arbitrary and unpredictable, preventing a defendant from making an argument for the appropriate situation. However, past instance of harm are appropriate foundations for punitive damages.
- Court
- Supreme Court
- Decision Date
- October 31, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
Watson v. Philip Morris Cos., 551 U.S. 142 (2007)
Consumer WonThe federal officer removal statute does not permit a defendant to remove a state-court action to federal court simply because a federal regulatory agency directs, supervises, and monitors the company’s activities in detail; the company must be acting under the direct authority of a federal officer in relation to the specific conduct being challenged.
Smith v. Massachusetts, 543 U.S. 462 (2005)
Consumer LostThe Double Jeopardy Clause prohibits a trial judge from reconsidering an acquittal once it has been formally entered, even if the judge believes that the initial acquittal was erroneous.
Unitherm Food Systems, Inc. v. Swift-Eckrich, Inc., 546 U.S. 394 (2006)
Consumer LostA party in a civil jury trial must file a motion for judgment as a matter of law under Federal Rule of Civil Procedure 50(b) after a jury verdict to preserve the right to challenge the sufficiency of the evidence on appeal; failure to do so precludes appellate review of the evidence's sufficiency.
Marshall v. Marshall, 547 U.S. 293 (2006)
Consumer WonThe Supreme Court held that the Ninth Circuit's broad interpretation of the probate exception, which excluded federal jurisdiction over matters related to the validity of a decedent's estate planning instruments, was unwarranted and not supported by Congressional intent or prior Supreme Court decisions.