process. The court held that punitive damages must be reasonable, as determined by the degree of reprehensibility of the conduct that caused the plaintiff's injury, the ratio of punitive damages to compensatory damages, and any comparable criminal or civil penalties applicable to the conduct. In State Farm Auto. Ins. v. Campbell (2003), the Supreme Court held that punitive damages might only be based on the acts of the defendants which harmed the plaintiffs. The court also elaborated on the factors courts must apply when reviewing a punitive award under due process principles. Most recently, in Philip Morris USA v. Williams (2007), the Supreme Court ruled that punitive damage awards cannot be imposed for the direct harm that the misconduct caused others, but may consider harm to others as a function of determining how reprehensible it was. More reprehensible misconduct justifies a larger punitive damage award, just as a repeat offender in criminal law may be punished with a tougher sentence. Dissenting in the Williams case, Justice John Paul Stevens found that the "nuance eludes me", suggesting that the majority had resolved the case on a distinction that makes no difference. Punitive damages are subjective by their very nature. Since their purpose is to punish—as opposed to compensate—opinions on how to accomplish this will vary widely among jurors. Regardless, research into punitive damages has revealed some common principles. Wealth of the defendant is positively correlated with large punitive damage awards, jurors either downplay or ignore jury instructions regarding punitive damages determinations, and jurors tend to punish defendants who have conducted a cost-benefit analysis. Important cases Pac. Mut. Life Ins. Co. v. Haslip, TXO Production Corp. v. Alliance Resources Corp., Honda Motor Co. v. Oberg, BMW of North America, Inc. v. Gore, Cooper Industries, Inc. v. Leatherman Tool Group, Inc., State Farm Mutual Automobile Insurance Co. v. Campbell, Philip Morris USA Inc. v. Williams, Exxon Shipping Co. v. Baker, See also Non-economic damages caps Collateral consequences of criminal conviction Penal bond Explanatory notes References Legal terminology Judicial remedies