J. Michael White, et al. v. Lindsay Davis, et al.
DueProcess JusticiabilityDoctri
Whether a private actor authorized by the state to collect sewer charges, acting on its own choices, constitutes a state actor, and whether a punitive damages award of 271,444 to 1 ratio bears a reasonable relationship to compensatory damages
QUESTION PRESENTED This Court has held that a private actor making it’s own choices under authority granted to it by the state, and acting on those choices, is not a state actor. The town of Lake View granted White authority to collect sewer charges and fees from customers and White chose to act in accordance with his authority. Did the court of appeals err when it held that White was state actor? This Court has held that a punitive damages award should bear some reasonable relationship to the corresponding award of compensatory damages. The jury awarded punitive damages of $2,443,000 on certain of the plaintiffs’ claims, and awarded compensatory damages of only $9 on those same claims. Did the court of appeals err when it found the 271,444 to 1 ratio of punitive to compensatory damages to be a reasonable relationship?