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William Large

Florida Justice Reform Institute President William Large called the state Supreme Court ruling a victory for textualism. | Florida Justice Reform Institute

Florida's high court rejects 'excessive' $16 million damages award in wrongful death case

By Michael Carroll - Jan 10, 2023

The Florida Supreme Court has struck down a $16 million punitive damages award in a wrongful death case, concluding that the award was out of sync with the jury’s compensatory damages award of just $150,000.

In a Jan. 5 ruling in the case of Brinda Coates vs. R.J. Reynolds Tobacco Co., the high court said trial courts abuse their discretion when they reject a party’s request to reduce punitive damages awards which appear unreasonable when compared with compensatory damages and the plaintiff’s injury.

In turn, the state Supreme Court affirmed a state appeals court’s ruling in the case, in which R.J. Reynolds was accused of being partly liable for the death of Coates’ sister, Lois Stucky, as a result of Stucky’s use of the company’s tobacco products.

“We approve the Fifth District’s decision reversing the punitive damages award and remanding for further proceedings to the extent the district court’s decision is consistent with this opinion,” the Supreme Court’s opinion states.

The Florida Justice Reform Institute (FJRI) and American Tort Reform Association (ATRA) view the high court’s decision as a victory for the rule of law.

“As the court noted in its opinion, ‘judicial discretion must be constrained by statutory criteria in determining whether an award is excessive,’ ” William Large, FJRI’s president, said in a statement emailed to the Florida Record. “This is a huge win for textualism and the notion that the judiciary’s role is to say what the law is and not what it should be.”

The FJRI, ATRA and the U.S. Chamber of Commerce previously filed an amicus brief in the case. The brief argues that a 1997 state law makes a punitive damages award greater than three times the compensatory damages award “presumptively invalid.” In the Coates case, the ratio of the two awards was 106.7 to 1.

The high court did acknowledge the possibility that a trial judge could make a finding that a punitive damages award reasonably exceeds the 3:1 ratio based on the facts and circumstances of a case. But such a finding has to show a reasonable relationship between “the amount of damages proved and the injury suffered,” the justices said.

The Record is owned by the U.S. Chamber of Commerce’s Institute for Legal Reform.