Pacific Mutual Life Ins. Co. v. Haslip

Health insurance premiums of Cleopatra Haslip and others (plaintiffs) were paid to Lemmie Ruffin, Jr., an agent (defendant) of Pacific Mutual Life Insurance Co. (Pacific Mutual) (defendant). The agent misappropriated the premiums. When Haslip was hospitalized, she could not secure insurance coverage to pay for her treatment. Consequently, a judgment for medical debt was rendered against her. Plaintiffs filed a lawsuit against Pacific Mutual and its agent in an Alabama state court. At trial, in accordance with Alabama state law, the court instructed the jurors that if they found defendants liable for fraud, they could choose to award—or not—punitive damages in order to “punish” defendants and “protect[ ] the public.” The court further instructed the jurors that they were to consider, in making a punitive damages determination, “the character and the degree of the wrong” as well as the need to prevent similar wrongs in the future. Defendants did not object to the charge as being too general, nor did they request more specific instructions. The jury found in favor of plaintiffs and awarded punitive damages. The Alabama Supreme Court affirmed the award after considering it in relation to numerous factors. Pacific Mutual petitioned the United States Supreme Court for certiorari, asserting that the degree of discretion given to the jury violated its rights of due process.