On February 27, 2014, the Virginia Supreme Court handed down Coalson v. Canchola, No. 130837, an automobile accident case in which it reinstated a punitive damages award of $100,000.00 that had been remitted to $50,000.00 by the trial court under protest by Plaintiff. Coalson held that the $100,000.00 punitive damages was not excessive under Virginia law and did not violate the Due Process Clause of the Fourteenth Amendment, even though the underlying compensatory damages awarded were only $5,600.00. Id. at 1-2, 15.
Coalson held it was error to compare “relative ratios of compensatory damages to punitive damages as a basis for granting remitter”. Id. at 9. It also held the “punitive damages are reasonably related to [the victim’s] actual damages and to the degree of necessary punishment, which in this case is great,” despite the “[‘high’ but not ‘unreasonable or strikingly out of proportion’] ratio of Coalson’s compensatory damages to punitive damages awarded by the jury is 1:17.86;”. id. at 10: “the amount of punitive damages awarded by the jury does not shock the Court’s conscience”. Id. at 11.