On January 5, 2023, the Florida Supreme Court provided much-needed guidance to lower Florida courts on how to evaluate punitive damages awards in wrongful death actions. The court held that the trial court’s $16 million punitive damages award bore no reasonable relation to the amount of damages proved and the injury suffered under Florida law. The decision was a victory for WLF, which filed an amicus brief in the case. The case arose from a wrongful death action against R.J. Reynolds Tobacco Company. After awarding the plaintiff $150,000 solely on her design-defect claim, the jury awarded her a staggering $16 million in punitive damages. That award produced an eye-popping 106:1 punitive-to-compensatory ratio. The Florida statutes require a punitive damages award in a wrongful death action to bear a reasonable relation to the amount of damages proved and the injury suffered by the statutory beneficiaries. According to the Florida high court, the trial court’s outsized award flunked that test. Because the appeal could be resolved on a statutory basis alone, the court declined to further analyze the issue as a matter of Florida or federal constitutional law.
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