California Court of Appeal August 17, 2011, No. B222596 (Bullock v. Philip Morris USA, Inc.)

KITCHING, J., Dissenting.

In State Farm Mut. Automobile Ins. Co. v. Campbell (2003) 538 U.S. 408 [155 L.Ed.2d 585, 123 S.Ct. 1513] (State Farm), the United States Supreme Court addressed the circumstances under which an award of punitive damages violates the due process clause of the Fourteenth Amendment to the Constitution of the United States.