Philip Morris USA v. Williams

Brief Fact Summary.

Punitive damages were potentially awarded based on harm to people not a party to the litigation.

Synopsis of Rule of Law.

Punitive damages cannot be awarded for injury suffered by non-parties to the litigation.

Facts.

Plaintiff represents a woman who died from the effects of long term cigarette smoking.  Defendant manufactured the deceased’s preferred brand of cigarettes.  In earlier proceedings, a jury found the defendant guilty of negligence, and awarded, among other damages, 79.5 million dollars of punitive damages, which was then reduced by half on appeal.  Both sides appeal the question of whether the jury was properly instructed regarding the award of damages as it relates to people not a party to the litigation.

Issue.

Can punitive damages be awarded for injury to people not part of the litigation?

Held.

No, punitive damages cannot be awarded for conduct against people not a party to the litigation.

Discussion.

The court found in favor of the defendant, and ruled that punitive damages cannot be awarded for injuries suffered by people not a party to the litigation.  In coming to this conclusion, they reasoned that to allow this to occur would deprive those not currently a party to the litigation of their ability to recover their share of the damages if they engaged in future litigation.  The court also opined that it would be an improper violation of due process to allow recovery of punitive damages in instances where the harmed party were not involved in the litigation because it deprives the defendant the opportunity to litigate against those claims.