In recent years, the standard by which Arizona courts examine the validity of punitive damage claims has been molded by rulings from the United States Supreme Court. In 2003, in State Farm Mut. Auto Ins. Co. v. Campbell , the United States Supreme Court struck down a $145 million dollar punitive damage award in a bad faith case and set forth legal principles that will make it more challenging for litigants to secure multimillion-dollar punitive damage awards in the future. State Farm Mut. Auto Ins. Co. v. Campbell, 538 U.S. 408 (2003). The ruling in Campbell continued the Court’s efforts to reform punitive damage award guidelines that were initially set forth in BMW of North America, Inc. v. Gore, 517 U.S. 559 (1996).

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