the punitive award is, not surprisingly, unconstitutionally excessive, according to the Ninth Circuit in Southern Union Co. v. Southwest Gas Corp., (Ninth Circuit July 13, 2005). In so holding, the court rejected the district court's conclusion that the extraordinarily high ratio was justified because the case involved "reprehensible conduct" by a public official and held that the district court erred by relying on civil rights cases to set a benchmark for the damages ratio in a private tort action.
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