The Supreme Court released its opinion in Exxon Shipping Co. v. Baker, No. 07-219, the landmark Exxon Valdez case, holding that the $2.5 billion punitive damages award is excessive as a matter of maritime law and that "a 1:1 ratio" of punitive to compensatory damages " is a fair upper limit" in maritime cases. What are the implications of this decision for due process challenges to punitive damages awards in the future?