In 1993, Justice O’Connor observed that “time and again, this Court and its Members have expressed concern about punitive
damages awards ‘run wild,’ inexplicable on any basis but caprice or passion.” Three years later, in BMW of North America, Inc. v. Gore, the Court took a significant step toward reining in excessive punitive damages awards when it held that the Due Process Clause of the Fourteenth Amendment imposes substantive constitutional limits on the amount of punitive damages awarded.

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