## Facts

- Charles Clark died after a collision while driving a 1992 Dodge Ram club cab pickup; he was not wearing a seat belt, was ejected from the vehicle, and died shortly after.
- Dorothy Clark (his widow) sued Chrysler, alleging defective design of the door-latch/door-frame system and failure to warn, claiming the “unboxed” latch/frame design was structurally weak, outdated, and prone to failure, increasing the risk of ejection in a crash.
- Plaintiff presented evidence that Chrysler allegedly knew ejection substantially increases fatality risk but did not perform tests aimed at latch failure in collisions.
- Chrysler contested defect, causation (including whether a “boxed” design would have prevented ejection), and the need for additional testing.
- A jury found Chrysler and Charles Clark each 50% at fault and awarded $471,258.26 in compensatory damages and $3,000,000 in punitive damages; the district court entered judgment for 50% of compensatories plus the full punitive award.
- After an earlier appeal and a Supreme Court vacatur/remand for reconsideration in light of State Farm, the district court again upheld the punitive award; Chrysler appealed solely as to punitive damages.

## Issues

1. Whether the $3,000,000 punitive damages award was constitutionally excessive under the Due Process Clause applying BMW of North America, Inc. v. Gore and State Farm Mutual Automobile Insurance Co. v. Campbell.
2. If excessive, what remitted punitive amount would satisfy due process in view of reprehensibility, punitive-to-compensatory ratio, and comparable statutory penalties.

## Decision

- The Sixth Circuit held the $3,000,000 punitive damages award was constitutionally excessive.
- The court reversed the order upholding the $3,000,000 punitive award and remitted punitive damages to $471,258.26 (equal to the jury’s compensatory award).
- Liability and compensatory damages were left intact; only the punitive amount was reduced.

## Legal Principles

- Due process limits punitive damages; courts evaluate constitutionality using the Gore/State Farm guideposts: (1) reprehensibility, (2) ratio of punitive to compensatory damages, and (3) comparison to civil or statutory penalties for similar misconduct.
- When compensatory damages are substantial, State Farm indicates that a 1:1 punitive-to-compensatory ratio may approach the constitutional limit absent exceptionally egregious conduct.
- Comparative fault and the absence of intentional or malicious targeting may reduce the constitutionally permissible level of punitive damages.
- Large punitive awards that greatly exceed comparable statutory civil penalties may signal constitutional excessiveness.

## Conclusion

The Sixth Circuit concluded that punitive damages were permissible but that $3,000,000 exceeded due process limits given the substantial compensatory award, shared fault, and the nature of the misconduct; it reduced punitive damages to $471,258.26 to align with the Gore and State Farm constraints.


Clark v. Chrysler Corp., 436 F.3d 594 (6th Cir. 2006)