Reforming Reprehensibility: The Continued Viability of Multiple Punitive Damages After State Farm v. Campbell

In this Article, the author discusses how the Supreme Court's recent decision in State Farm v. Campbell reformed the reprehensibility analysis and how this reformation may have the perhaps unintended consequence of eliminating the practice of awarding total harm damages. In particular, in an effort to limit the size of individual punitive damage awards, Campbell limits the use of evidence of conduct directed at parties not before the court.