State Limits: Can One State Rule the Country? One State Awarding Punitive Damages for Nationwide Conduct

Abstract

This article analyzes what the State Farm case adds to the body of punitive damages law with regard to the use of extraterritorial conduct. The four seminal cases that refined the punitive damages canon prior to the State Farm case are discussed in Part II. Extraterritorial conduct is reviewed in Part III: its current use, a Ninth Circuit decision that confronted an issue similar to the one in State Farm, and finally the State Farm case itself. Part IV concludes by discussing the future ramifications for punitive damages awards.