BMW of North America v. Gore
**Overview of BMW of North America v. Gore**
BMW of North America v. Gore is a significant legal case that arose from a dispute between a consumer and the automobile manufacturer regarding undisclosed vehicle damage. The case began when Ira Gore purchased a new BMW, only to discover later that the car had been repainted due to prior damage, which he claimed was not disclosed by BMW. Gore filed a lawsuit under Alabama law, alleging fraud, and was initially awarded $4,000 in compensatory damages and a substantial $2 million in punitive damages. However, the Supreme Court ultimately intervened, ruling by a narrow 5-4 margin that the punitive damages awarded were excessive and not justified by BMW's conduct. Justice John Paul Stevens, writing for the majority, highlighted the necessity for a "reasonable relationship" between punitive damages and the actual harm experienced by the plaintiff. The case raises important questions about the limits of punitive damages and their alignment with due process, as discussed in the dissenting opinion of Justice Antonin Scalia, who expressed concern over the implications for civil jury decisions. Overall, BMW of North America v. Gore illustrates the complexities involved in consumer protection law and the judicial evaluation of damages in the civil litigation system.
BMW of North America v. Gore
Date: May 20, 1996
Citation: 116 S.Ct. 1589
Issues: Excessive damage awards; substantive due process
Significance: The Supreme Court held that a punitive damage award of five hundred times the amount of actual damages was “grossly excessive” and therefore contrary to the due process clause of the Fourteenth Amendment.
After Ira Gore purchased a new BMW, he found that it had been repainted by the manufacturer. Alleging fraud according to Alabama law, Gore brought suit against BMW for failure to disclose a defect. He was awarded $4,000 in compensatory damages and $2 million in punitive damages. By a 5-4 margin, the Supreme Court found that BMW’s conduct was not egregious enough to justify such an extreme sanction. Writing for the Court, Justice John Paul Stevens emphasized that there must be a “reasonable relationship” between a punitive damages award and any conceivable harm that the plaintiff might suffer. In dissent, Justice Antonin Scalia criticized the expansion of the substantive due process doctrine to include jury decisions in civil suits.
