Holdgrafer v. Unocal Corp.

Opinion

PERREN, J.

In deciding whether a punitive damages award violates the constitutional prohibition of arbitrary or grossly excessive punishment, the most important factor to be considered is the reprehensibility of the defendant’s conduct. The United States Supreme Court has instructed courts undertaking this inquiry that “[a] defendant’s dissimilar acts, independent from the acts upon which liability was premised, may not serve as the basis for punitive damages.” On de novo review, we conclude that evidence of two massive oil spills is too dissimilar to be considered in assessing…