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Keywords

contractdamagesappealtrialmotiontrustantitrustdue processpunitive damagescompensatory damagesrespondentpost-trial motion
contracttortdamagestrustantitrustpunitive damagesrespondentexemplary damages

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Browning-Ferris Industries of Vermont, Inc. v. Kelco Disposal, Inc., 492 U.S. 257, 109 S.Ct. 2909, 106 L.Ed.2d 219, 57 USLW 4985, 1989-1 Trade Cases P 68,630

Facts

Respondents Joseph Kelley and Kelco Disposal, Inc. filed suit against BFI, alleging antitrust violations and interference with contractual relations. A jury found BFI liable and awarded Kelco $51,146 in compensatory damages and $6 million in punitive damages. BFI's attempts to drive Kelco out of business included drastic price cuts and aggressive tactics, which led to Kelco capturing a significant market share. BFI's post-trial motions for a new trial or remittitur were denied by the District Court.

Respondents Joseph Kelley and Kelco Disposal, Inc., filed suit against petitioners (collectively BFI) in Federal District Court, charging BFI with antitrust violations and with interfering with Kelco's contractual relations in violation of Vermont tort law.

Issue

Whether the Excessive Fines Clause of the Eighth Amendment applies to punitive damages awarded in civil cases between private parties.

We face here the questions whether the Excessive Fines Clause of the Eighth Amendment applies to a civil-jury award of punitive or exemplary damages, and, if so, whether an award of $6 million was excessive in this particular case.

Rule

The Eighth Amendment's Excessive Fines Clause does not apply to punitive damages awarded in civil cases between private parties, and there is no federal common-law standard for reviewing the excessiveness of such awards.

The Excessive Fines Clause of the Eighth Amendment does not apply to punitive damages awards in cases between private parties; it does not constrain such an award when the government neither has prosecuted the action nor has any right to recover a share of the damages awarded.

Analysis

The court determined that the Eighth Amendment was primarily concerned with governmental abuse of power in criminal contexts, not with civil damages awarded by juries in private disputes. The court found that the punitive damages awarded were not so disproportionate as to be considered excessive, even if the Eighth Amendment were applicable. Additionally, BFI's failure to preserve its due process claim regarding the punitive damages award meant that the court would not consider it.

The court noted that even if the Amendment were applicable 'to this nominally civil case,' the damages were not 'so disproportionate as to be cruel, unusual, or constitutionally excessive,' and upheld the award.

Conclusion

The Supreme Court affirmed the Court of Appeals' decision, holding that the Eighth Amendment's Excessive Fines Clause does not apply to punitive damages in private civil cases and that the punitive damages awarded were not excessive.

Affirmed.

Who won?

Kelco Disposal, Inc. prevailed in the case, as the court upheld the jury's award of punitive damages, finding no abuse of discretion by the District Court.

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