Automobile Fraud: 8.11.3.1.1 Gore, State Farm, and Philip Morris
The second guidepost identified by Gore and State Farm for determining the constitutionality of a punitive damages award is the ratio of punitive damages to compensatory damages. Gore did not suggest numerical standards for the ratio. In State Farm, while rejecting a “bright-line ratio,” the Court warned that “in practice, few awards exceeding a single-digit ratio between punitive and compensatory damages, to a significant degree, will satisfy due process.”596