Lithia Medford LM, Inc. v. Yovan

In a small-damages case, punitive damages can exceed a single digit ratio where, in consideration of similar cases and the deterrent function it serves, the punitive damage award is not grossly excessive.

Yovan prevailed on a claim against Lithia Medford LM (Lithia) under the Oregon Unlawful Debt Collection Practice Act, where he was awarded $500 in noneconomic damages and $100,000 in punitive damages. The trial court concluded that the punitive damages award was too large, and reduced it to $2,000. Yovan appealed, the decision was affirmed by a divided Court of Appeals, and the case was back in Court of Appeals on remand from the Oregon Supreme Court for consideration in light of Hamlin II, which analyzed punitive damage awards in small-damages cases. Here, the Court of Appeals held that in such small-damage cases, the punitive damage award can constitutionally exceed a single-digit ratio. In considering other similar cases and its deterrent function, the jury award of $100,000 in punitive damages is not grossly excessive. Thus, the trial court erred in reducing Yovan's punitive damage award to $2,000. Reversed and remanded to reinstate jury's award.