Landau, J. Aaron2009-05-192009-05-1920080196-2043https://hdl.handle.net/1794/917933 p.Part I of this Comment summarizes the history of punitive damages jurisprudence leading up to the conflict in Philip Morris. Part II discusses the factual and procedural history of Philip Morris and explains the Supreme Court’s holding in the case. Part III analyzes the Court’s reasoning and the problems it presents upon real-world application. Part IV concludes this Comment by briefly discussing an alternative approach that is both clearer than the Court’s standard and more protective of a defendant’s rights under the Due Process Clause.en-USArticle