In Coates, the Florida Supreme Court held that a trial court in a wrongful death action abuses its discretion by denying remittitur of a punitive damages award that does not bear a reasonable relation to the damages proved and the injuries suffered by the statutory beneficiaries.
In the underlying case, an estate brought a wrongful death action against R.J. Reynolds Tobacco Co., alleging that the decedent died as a result of lung cancer caused by smoking cigarettes. The jury found R.J. Reynolds liable on a strict liability claim and awarded $150,000 in compensatory damages against R.J. Reynolds. The jury’s verdict specified that the compensatory damages were to compensate the decedent’s children for the loss of parental companionship, instruction, and guidance, and for their mental pain and suffering as a result of their mother’s lung cancer and death. However, the jury also awarded the plaintiff $16 million in punitive damages. R.J. Reynolds filed a motion for new trial or remittitur to reduce the damages award, arguing that the punitive damages award was excessive, which the trial court denied. On appeal, the Fifth District reversed the punitive damages award as excessive under both Florida and federal law.
The Florida Justice Reform Institute, in an amicus brief joined by the U.S. Chamber of Commerce and the American Tort Reform Association, argued to the Florida Supreme Court that a punitive damages award that is 106.7 times a substantial compensatory damages award is excessive and facially unlawful.
The Florida Supreme Court agreed, finding that the trial court abused its discretion in denying remittitur because no reasonable trial court could have concluded that a $16 million punitive damages award bears a reasonable relation to a $150,000 compensatory damages award.
Accordingly, the Court approved the Fifth District’s decision reversing the punitive damages award.
The Institute was represented by William W. Large and Joseph H. Lang, Jr., of Carlton Fields, P.A.