Cooper Industries, Inc. v. Leatherman Tool Group, Inc.

Summary

The Court held that appellate courts must review de novo a district court's determination whether punitive damages are constitutionally excessive, while reviewing underlying factual findings for clear error. Such review does not violate the Seventh Amendment because the amount of punitive damages is not itself a jury finding of fact. The Court vacated the Ninth Circuit's judgment and remanded without deciding whether the $4.5 million award was unconstitutional. Justice Thomas concurred without joiners, joining the Court's opinion while maintaining that BMW v. Gore should be overruled in an appropriate case. Justice Scalia concurred in the judgment without joiners because existing precedents supported de novo review, notwithstanding his disagreement with those precedents. Justice Ginsburg dissented without joiners, arguing that Seventh Amendment considerations and trial courts' institutional advantages required abuse-of-discretion review and that the judgment should be affirmed.