ARTICLE · 06 JULY 2005

California Supreme Court Clarifies Guidelines for Punitive Damages

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Two years after the U.S. Supreme Court’s opinion in State Farm v. Campbell, the California Supreme Court has clarified the guidelines for imposition of punitive damages in Simon v. San Paolo U.S. Holding Co. and Johnson v. Ford Motor Co.

United StatesLitigation, Mediation & Arbitration

Jedediah Wakefield

Jennifer Fraser Parrish

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Two years after the U.S. Supreme Court’s opinion in State Farm v. Campbell, the California Supreme Court has clarified the guidelines for imposition of punitive damages in Simon v. San Paolo U.S. Holding Co. and Johnson v. Ford Motor Co.

The California Supreme Court issued two important rulings in June 2005, taking up the constitutionality of punitive damage awards in light of the guidelines established by the U.S. Supreme Court in State Farm Mutual Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003). In Simon v. San Paolo U.S. Holding Co., 05 C.D.O.S. 5207 (2005), the court reduced the punitive damages awarded from $1.7 million to $50,000. In Johnson v. Ford Motor Co., 05 C.D.O.S. 5215 (2005), the court reversed the appellate court’s reduction of a jury award of $10 million to $53,435 and remanded for further consideration.

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