Honda Motor Co. v. Oberg

Last updated
Honda Motor Company v. Oberg
Seal of the United States Supreme Court.svg
Argued April 20, 1994
Decided June 24, 1994
Full case nameHonda Motor Company, Ltd., et al., Petitioners v. Karl L. Oberg
Citations512 U.S. 415 ( more )
114 S. Ct. 2331; 129 L. Ed. 2d 336; 1994 U.S. LEXIS 4825; 62 U.S.L.W. 4627; CCH Prod. Liab. Rep. ¶ 13,895; 94 Cal. Daily Op. Service 4761; 94 Daily Journal DAR 8844; 8 Fla. L. Weekly Fed. S 341
Holding
Oregon's 1910 state constitutional amendment prohibiting a judicial review of jury awards violates the Due Process Clause of the Fourteenth Amendment.
Court membership
Chief Justice
William Rehnquist
Associate Justices
Harry Blackmun  · John P. Stevens
Sandra Day O'Connor  · Antonin Scalia
Anthony Kennedy  · David Souter
Clarence Thomas  · Ruth Bader Ginsburg
Case opinions
MajorityStevens, joined by Blackmun, O'Connor, Scalia, Kennedy, Souter, Thomas
ConcurrenceScalia
DissentGinsburg, joined by Rehnquist
Laws applied
U.S. Const. amend. XIV

Honda Motor Company v. Oberg, 512 U.S. 415 (1994), was a United States Supreme Court case in which the Court held that an amendment to the Oregon state constitution disallowing judicial review of the size of punitive damages was a violation of due process. [1]

Contents

Decision

In a products liability action, Honda was found liable for injuries received by the plaintiff in an ATV accident. Honda was liable for a $5 million punitive damage award, and both the state appellate court and the Oregon Supreme Court declined to review the award for excessiveness based on an amendment to the Oregon constitution. The Supreme Court of United States held that the amendment to the Oregon constitution violated due process. The Court held that judicial review of punitive damage awards for excessiveness was a long-standing common law tradition that was critical in protecting against arbitrary deprivations of property, and that Oregon had not instituted a substitute procedure to maintain these protections. [2]

See also

Related Research Articles

<span class="mw-page-title-main">Eighth Amendment to the United States Constitution</span> 1791 amendment regulating forms of punishment

The Eighth Amendment to the United States Constitution protects against imposing excessive bail, excessive fines, or cruel and unusual punishments. This amendment was adopted on December 15, 1791, along with the rest of the United States Bill of Rights. The amendment serves as a limitation upon the federal government to impose unduly harsh penalties on criminal defendants before and after a conviction. This limitation applies equally to the price for obtaining pretrial release and the punishment for crime after conviction. The phrases in this amendment originated in the English Bill of Rights of 1689.

Punitive damages, or exemplary damages, are damages assessed in order to punish the defendant for outrageous conduct and/or to reform or deter the defendant and others from engaging in conduct similar to that which formed the basis of the lawsuit. Although the purpose of punitive damages is not to compensate the plaintiff, the plaintiff will receive all or some of the punitive damages in award.

Substantive due process is a principle in United States constitutional law that allows courts to establish and protect certain fundamental rights from government interference, even if procedural protections are present or the rights are unenumerated elsewhere in the U.S. Constitution. Courts have asserted that such protections come from the due process clauses of the Fifth and Fourteenth amendments to the U.S. Constitution, which prohibit the federal and state governments, respectively, from depriving any person of "life, liberty, or property, without due process of law". Substantive due process demarks the line between those acts that courts hold to be subject to government regulation or legislation and those that courts place beyond the reach of governmental interference. Whether the Fifth or Fourteenth Amendments were intended to serve that function continues to be a matter of scholarly as well as judicial discussion and dissent. Justice Clarence Thomas has called on the Supreme Court to reconsider all of its rulings that were based on substantive due process.

In United States constitutional law, a Due Process Clause is found in both the Fifth and Fourteenth Amendments to the United States Constitution, which prohibits arbitrary deprivation of "life, liberty, or property" by the government except as authorized by law.

Skinner v. State of Oklahoma, ex rel. Williamson, 316 U.S. 535 (1942), was a unanimous United States Supreme Court ruling that held that laws permitting the compulsory sterilization of criminals are unconstitutional as it violates a person's rights given under the 14th Amendment of the United States Constitution, specifically the Equal Protection Clause, as well as the Due Process Clause. The relevant Oklahoma law applied to "habitual criminals", but the law excluded white-collar crimes from carrying sterilization penalties.

In United States constitutional law, a state actor is a person who is acting on behalf of a governmental body, and is therefore subject to limitations imposed on government by the United States Constitution, including the First, Fifth, and Fourteenth Amendments, which prohibit the federal and state governments from violating certain rights and freedoms.

BMW of North America, Inc. v. Gore, 517 U.S. 559 (1996), was a United States Supreme Court case limiting punitive damages under the Due Process Clause of the Fourteenth Amendment.

Dolan v. City of Tigard, 512 U.S. 374 (1994), more commonly Dolan v. Tigard, is a United States Supreme Court case. It is a landmark case regarding the practice of zoning and property rights, and has served to establish limits on the ability of cities and other government agencies to use zoning and land-use regulations to compel property owners to make unrelated public improvements as a condition to getting zoning approval, citing the violation of the Fifth Amendment’s Takings Clause.

Philip Morris USA v. Williams, 549 U.S. 346 (2007), 556 U.S. 178 (2009), was a decision by the Supreme Court of the United States, which held that the due process clause of the Fourteenth Amendment limits punitive damages, and ordered a lower court to reconsider its damages awards on that basis.

Cooper Industries, Inc. v. Leatherman Tool Group, Inc., 532 U.S. 424 (2001), was a decision by the United States Supreme Court involving the standard of review that Federal Appeal Courts should use when examining punitive damages awards.

<span class="mw-page-title-main">Fifth Amendment to the United States Constitution</span> 1791 amendment enumerating due process rights

The Fifth Amendment (Amendment V) to the United States Constitution addresses criminal procedure and other aspects of the Constitution. It was ratified, along with nine other articles, in 1791 as part of the Bill of Rights. The Fifth Amendment applies to every level of the government, including the federal, state, and local levels, in regard to a US citizen or resident of the US. The Supreme Court furthered the protections of this amendment through the Due Process Clause of the Fourteenth Amendment.

Browning-Ferris Industries v. Kelco Disposal, 492 U.S. 257 (1989), was a case in which the Supreme Court of the United States held that the Eighth Amendment's prohibition of unreasonable fines does not apply to punitive-damage awards in civil cases when the United States is not a party.

Crowell v. Benson, 285 U.S. 22 (1932) is the landmark United States Supreme Court administrative law decision that outlined the adjudicatory authority of administrative agencies under Article III of the Constitution. The Court held that the United States Employees' Compensation Commission satisfied Fifth Amendment Due Process and the requirements of Article III with its court-like procedures and because it invests the final power of decision in Article III courts.

State Farm Mutual Automobile Insurance Co. v. Campbell, 538 U.S. 408 (2003), was a case in which the United States Supreme Court held that the due process clause usually limits punitive damage awards to less than ten times the size of the compensatory damages awarded and that punitive damage awards of four times the compensatory damage award is "close to the line of constitutional impropriety".

<i>Sony BMG Music Entertainment v. Tenenbaum</i>

Sony BMG Music Entertainment v. Tenenbaum is the appeals lawsuit which followed the U.S. District Court case Sony BMG v. Tenenbaum, No. 07cv11446-NG.

Smith v. California, 361 U.S. 147 (1959), was a U.S. Supreme Court case upholding the freedom of the press. The decision deemed unconstitutional a city ordinance that made one in possession of obscene books criminally liable because it did not require proof that one had knowledge of the book's content, and thus violated the freedom of the press guaranteed in the First Amendment. Smith v. California continued the Supreme Court precedent of ruling that questions of freedom of expression were protected by the Due Process Clause of the Fourteenth Amendment from invasion by state action. It also established that in order for one to be criminally liable for possession of obscene material, there must be proof of one's knowledge of the material.

The United States Constitution contains several provisions related to criminal sentencing.

TXO Production Corp. v. Alliance Resources Corp., 509 U.S. 443 (1993), was a decision by the Supreme Court of the United States, which upheld the decision of the West Virginia state court awarding $19,000 in compensatory damages and $10 million in punitive damages to the plaintiff. Although multiple justices recognized that the punitive damages were 526 times the compensatory damages, the Court held a "general concern of reasonableness" should guide courts in determining constitutionally acceptable damages under the due process clause of the Fourteenth Amendment.

References

  1. Varat, J.D. et al. Constitutional Law Cases and Materials, Concise Thirteenth Edition. Foundation Press, New York, NY: 2009, p. 358
  2. Varat, p. 358