This Note will touch upon the numerous constitutional challenges the doctrine of punitive damages has faced, and will discuss noteworthy Supreme Court cases preceding Exxon Shipping Co. v. Baker at length, including BMW of North America, Inc. v. Gore, 5 as well as State Farm Mutual Automobile Insurance Co. v. Campbell. 6 This Note argues against the imposition of a strict one-to-one maximum ratio of punitiveto-compensatory damages. In light of the varying application of Exxon outside of the maritime context, such an imposition defeats the purpose of punitive damages by diluting their potential for deterrence, and it needlessly complicates the punitive-damages analysis
Klutinoty, Maria C.
"Exxon Shipping Co. v. Baker: Why the Supreme Court Missed the Boat on Punitive Damages,"
Akron Law Review: Vol. 43
, Article 6.
Available at: http://ideaexchange.uakron.edu/akronlawreview/vol43/iss1/6