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- Subject: PACIFIC MUTUAL LIFE INSURANCE CO. v. HASLIP, Syllabus
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-
- NOTE: Where it is feasible, a syllabus (headnote) will be released, as
- is being done in connection with this case, at the time the opinion is
- issued. The syllabus constitutes no part of the opinion of the Court but
- has been prepared by the Reporter of Decisions for the convenience of the
- reader. See United States v. Detroit Lumber Co., 200 U. S. 321, 337.
- SUPREME COURT OF THE UNITED STATES
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-
- Syllabus
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- PACIFIC MUTUAL LIFE INSURANCE CO. v.
- HASLIP et al.
-
-
- certiorari to the supreme court of alabama
-
- No. 89-1279. Argued October 3, 1990 -- Decided March 4, 1991
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- After respondents' health insurance lapsed when one Ruffin, an agent for
- petitioner insurance company and another, unaffiliated insurance company,
- misappropriated premiums issued by respondents' employer for payment to the
- other insurer, respondents filed an action for damages in state court,
- claiming fraud by Ruffin and seeking to hold petitioner liable on a
- respondeat superior theory. Following the trial court's charge instructing
- the jury that it could award punitive damages if, inter alia, it determined
- there was liability for fraud, the jury, among other things, returned a
- verdict for respondent Haslip of over $1 million against petitioner and
- Ruffin, which sum included a punitive damages award that was more than 4
- times the amount of compensatory damages Haslip claimed. The Supreme Court
- of Alabama affirmed, specifically upholding the punitive damages award.
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- Held: The punitive damages award in this case did not violate the Due
- Process Clause of the Fourteenth Amendment. Pp. 5-20.
-
- (a) Holding petitioner responsible for Ruffin's acts did not violate
- substantive due process. The jury's finding that Ruffin was acting within
- the scope of his apparent authority as an agent of petitioner when he
- defrauded respondents was not disturbed by the State Supreme Court and is
- amply supported by the record. Moreover, Alabama's longstanding common-law
- rule that an insurer is liable for both compensatory and punitive damages
- for the intentional fraud of its agent effected within the scope of his
- employment rationally advances the State's interest in minimizing fraud,
- since that rule creates a strong financial incentive for vigilance by
- insurers. Thus, imposing liability on petitioner under the respondeat
- superior doctrine is not fundamentally unfair. Pp. 9-12.
-
- (b) Since every state and federal court considering the question has
- ruled that the common-law method for assessing punitive damages does not in
- itself violate due process, it cannot be said that that method is so
- inherently unfair as to be per se unconstitutional. The method was well
- established before the Fourteenth Amendment was enacted, and nothing in the
- Amendment's text or history indicates an intention to overturn it. Pp.
- 12-15.
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- (c) Nevertheless, unlimited jury or judicial discretion in the fixing
- of punitive damages may invite extreme results that are unacceptable under
- the Due Process Clause. Although a mathmatical bright line cannot be drawn
- between the constitutionally acceptable and the constitutionally
- unacceptable that would fit every case, general concerns of reasonableness
- and adequate guidance from the court when the case is tried to a jury
- properly enter into the constitutional calculus. P. 15.
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- (d) The punitive damages assessed against petitioner, although large in
- comparison to the compensatory damages claimed by Haslip, did not violate
- due process, since the award did not lack objective criteria and was
- subject to the full panoply of procedural protections. First, the trial
- court's instructions placed reasonable constraints on the exercise of the
- jury's discretion by expressly describing punitive damages' purposes of
- retribution and deterrence, by requiring the jury to consider the character
- and degree of the particular wrong, and by explaining that the imposition
- of punitive damages was not compulsory. Second, the trial court conducted
- a post-verdict hearing that conformed with Hammond v. City of Gadsden, 493
- So. 2d 1374 (Ala.), which sets forth standards that ensure meaningful and
- adequate review of punitive awards. Third, petitioner received the benefit
- of appropriate review by the State Supreme Court, which applied the Hammond
- standards, approved the verdict thereunder, and brought to bear all
- relevant factors recited in Green Oil Co. v. Hornsby, 539 So. 2d 218
- (Ala.), for ensuring that punitive damages are reasonable. Pp. 15-20.
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- 553 So. 2d 537, affirmed.
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- Blackmun, J., delivered the opinion of the Court, in which Rehnquist, C.
- J., and White, Marshall, and Stevens, JJ., joined. Scalia, J., and
- Kennedy, J., filed opinions concurring in the judgment. O'Connor, J.,
- filed a dissenting opinion. Souter, J., took no part in the consideration
- or decision of the case.
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