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Sturm, Ruger & Co., Inc. v. Day

594 P.2d 38 (1979)

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Sturm, Ruger & Co., Inc. v. Day

Alaska Supreme Court

594 P.2d 38 (1979)

Facts

Michael James Day (plaintiff) was shot in the leg when his gun unexpectedly fired. Day had been unloading his gun, a .41 revolver made by Sturm, Ruger & Co. (Sturm) (defendant) that Day had bought new, when the gun slipped out of his hands. Day grabbed at the gun, and it fired, seriously injuring Day. Day filed a products-liability action against Sturm, and the jury found that the gun was designed defectively and had a manufacturing defect. Evidence at trial showed that Sturm management knew of the defects with the revolver, were aware of cases of serious injury caused by the defects, and that the additional cost to manufacture the revolvers without the defects would be $1.93 per gun. The jury was instructed that punitive damages were appropriate if Sturm knew that its design was defective and had caused injuries or death and if Sturm acted with reckless indifference toward its customers’ safety. The jury awarded Day $137,750 in compensatory damages and $2,895,000 in punitive damages. The punitive damages award was $1.93 times the number of revolvers sold. Sturm filed a motion for a new trial and requested the judge reduce the amount of punitive damages. The court denied the motion. Sturm appealed, arguing that punitive damages violated its constitutional right to due process, were contrary to public policy, and were excessive.

Rule of Law

Issue

Holding and Reasoning (Connor, J.)

Dissent (Burke, J.)

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