Should this Court grant a Writ of Certiorari:

1. to correct a pervasive error by many
lower courts, including the Third Circuit in this case,
which have misunderstood the precedents to mean that
a single-digit ratio creates a safe harbor and insulates a
punitive award from meaningful constitutional
scrutiny?

2. to rekindle the rule—which has been all
but abandoned by the lower courts—that when
compensatory damages are substantial, a 1:1 ratio is the
outermost limit of the due process guarantee?

3. to settle the confusion in the lower courts
as to whether the damage cap in Title VII is a penalty
in comparable cases—i.e., the third guidepost—and, if
so, how it should be applied?

Should this Court grant a Writ of Certiorari