This case implicates the due process limits on punitive damages when a plaintiff has already recovered substantial compensatory damages. See State Farm Mutual Auto Insurance Co. v. Campbell, 538 U.S. 408, 425 (2004); BMW of North America v. Gore, 517 U.S. 559, 582 (1996). "When compensatory damages are substantial, then a lesser ratio, perhaps only equal to compensatory damages, can reach the outermost limit of the due process guarantee." State Farm, 538 U.S. at 425. State Farm teaches that this concern is heightened when, as here, the plaintiff incurred only economic harm. Id. at 419, 426.

Whether the Due Process Clause of the Fourteenth Amendment requires a strict proportionality test for punitive damages awards when compensatory damages are substantial, particularly in cases involving economic harm