Coalson v. Canchola

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Victoria Coalson and Michael Stemke (together, Plaintiffs) were injured in an accident caused by Victor Canchola, who was intoxicated at the time of the accident. Plaintiffs each filed lawsuits against Canchola. A jury awarded Coalson $5,600 in compensatory damages and Stemke $14,000 in compensatory damages against Canchola. Plaintiffs were each awarded $100,000 each in punitive damages. Canchola filed a motion for remittitur of both punitive damages awards, arguing that the awards were excessive under Virginia law and the Due Process Clause of the Fourteenth Amendment. The circuit court concluded that Coalson’s award was arbitrarily made and remitted Coalson’s punitive damages to $50,000. Coalson appealed. The Supreme Court reversed and reinstated the jury verdict awarding Coalson $100,000 in punitive damages, holding that the circuit court erred in granting Canchola’s motion for remittitur because Coalson’s punitive damages award was not excessive under Virginia law, nor did it offend Canchola’s due process rights. View "Coalson v. Canchola" on Justia Law