Court of Appeals holds punitive damages award to be constitutionally excessive

In Estate of Goddard v. Farmers Ins. Co., the Court of Appeals (Haselton, J.) held that an award of punitive damages was constitutionally excessive where the ratio of punitive to compensatory damages was 16:1, the defendant's conduct was "egregiously unethical," but did not result in serious physical injury or demonstrate a lack of regard for "the health and safety of the consuming public."  The court concluded that under the circumstance, 3:1 was the constitutionally appropriate ratio of punitives to compensatories.

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