Hamlin v. HAMPTON LUMBER MILLS, INC.
246 P.3d 1121
Or.2011Background
- Hamlin was injured at Hampton Lumber Mills and Express Personnel did not provide proper lockout procedures.
- Upon healing, Hamlin sought reinstatement; Hampton Lumber refused, claiming Hamlin was a safety risk and disseminated that false claim.
- Jury awarded Hamlin $6,000 in lost wages and $175,000 in punitive damages; CA reduced punitive damages to a 4:1 ratio to compensatory.
- Hamlin sued under ORS 659A.043 for failure to reinstate and under ORS 654.062(5) for OSHA retaliation; compensatory damages included $6,000 and prejudgment interest.
- Court of Appeals reversed, finding punitive damages grossly excessive; Supreme Court granted review and reinstated the punitive award.
- Court emphasized flexibility in Gore Campbell guideposts, considering small compensatory damages and statutory reprehensibility when awarding punitive damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 22:1 punitive-to-compensatory ratio is grossly excessive | Hamlin argues ratio permissible given small comp damages and statutory violation. | Hampton contends Gore/Campbell require stricter, usually single-digit ratios. | Punitive award not grossly excessive; ratio permissible under circumstances. |
| Whether statutory violation (ORS 659A.043) can be a reprehensibility factor | Statutory breach signals heightened reprehensibility and deterrence need. | Reprehensibility should rely on Campbell/Gore factors, not statutory violation alone. | Statutory violation considered as part of reprehensibility; supports higher punitive amount. |
| Role of the ratio guidepost when compensatory damages are small | Ratio exceptions can apply even with small compensatory damages to reflect deterrence. | Ratio guidepost should limit punitive to single-digit multipliers unless extraordinary. | Ratio guidepost flexible; does not require rigid single-digit ratio in all small-damages cases. |
| Whether Court should remand or remittitur apply to keep within due process | Full jury award should stand given overall deterrence and statutory aims. | Remittitur or appellate adjustment may be needed to avoid due process violation. | Court reinstates the jury’s punitive award; no remittitur required. |
| How comparative penalties (e.g., Title VII caps) affect the analysis | Comparable sanctions support the reasonableness of the award. | Federal caps do not dictate state punitive damages beyond due process considerations. | Punitive damages considered within state goals; not displaced by Title VII caps. |
Key Cases Cited
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003) (three Gore guideposts for reviewing punitive damages)
- BMW of North America, Inc. v. Gore, 517 U.S. 559 (1996) (establishes ratio and guidepost framework)
- Exxon Shipping Co. v. Baker, 554 U.S. 471 (2008) (exceptional context for compensatory-small damages and due process)
- Goddard v. Farmers Ins. Co., 344 Or. 232 (2008) (single-digit ratio generally; discusses Oregon approach)
- Jensen v. Medley, 336 Or. 222 (2003) (state-law background for favorable-fact standard in appellate review)
- Williams v. Philip Morris Inc., 340 Or. 35 (2006) (noted exception context for particularly egregious acts)