Should this Court grant a Writ of Certiorari

QUESTIONS PRESENTED 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?