Back More
Salem Press

Table of Contents

The Bill of Rights, 2nd Edition

BMW of North America v. Gore

by Thomas Tandy Lewis

Citation: 517 U.S. 559

Announced: May 20, 1996

Issues: Excessive damage awards; substantive due process

Relevant Amendments: Fifth and Fourteenth

Brief Summary: The Supreme Court held that a punitive damage award of five hundred times the amount of actual damages was “grossly excessive” and therefore contrary to the Due Process Clause of the Fourteenth Amendment.

After Ira Gore purchased a new BMW, he found that it had been repainted by the manufacturer. Alleging fraud according to Alabama law, Gore brought suit against BMW for failure to disclose a defect. He was awarded $4,000 in compensatory damages and $2 million in punitive damages. By a 5-4 margin, the Supreme Court found that BMW’s conduct was not egregious enough to justify such an extreme sanction. Writing for the Court, Justice John Paul Stevens emphasized that there must be a “reasonable relationship” between a punitive damages award and any conceivable harm that the plaintiff might suffer. In dissent, Justice Antonin Scalia criticized the expansion of the substantive due process doctrine to include jury decisions in civil suits.

Citation Types

Type
Format
MLA 9th
Lewis, Thomas Tandy. "BMW Of North America V. Gore." The Bill of Rights, 2nd Edition, edited by Thomas Tandy Lewis, Salem Press, 2017. Salem Online, online.salempress.com/articleDetails.do?articleName=BOR2e_0175.
APA 7th
Lewis, T. T. (2017). BMW of North America v. Gore. In T. T. Lewis (Ed.), The Bill of Rights, 2nd Edition. Salem Press. online.salempress.com.
CMOS 17th
Lewis, Thomas Tandy. "BMW Of North America V. Gore." Edited by Thomas Tandy Lewis. The Bill of Rights, 2nd Edition. Hackensack: Salem Press, 2017. Accessed December 14, 2025. online.salempress.com.