In the late hours of March 23, 1989, the Exxon Valdez supertanker moved through the waters of Prince William Sound off the coast of Alaska, en route to deliver fifty-three million gallons of crude oil to the lower forty-eight states. Steering the vessel was Captain Joseph Hazelwood, still intoxicated from the five double vodkas he drank in the waterfront bars of Valdez just prior to leaving port. As the clock approached midnight, just minutes before the ship was scheduled to make a required turn, Captain Hazelwood abruptly and inexplicably abandoned the bridge to return to his cabin. With no one to properly navigate the scheduled turn, the supertanker grounded on the reefbelow, causing the hull to fracture, spilling eleven million gallons of crude oil into the waters of Prince William Sound. These events amounted to the worst oil spill in American history and ignited an eruption of litigation, which now seems, after twenty years, to have reached its final act. . .
This Note explores the flaws underlying the Court’s reliance on the punitive-to-compensatory ratio as a barometer of due process and argues that the Court should realign its approach to evaluating constitutional excessiveness in order to preserve the punishment and deterrence objectives of punitive damages. Part II offers insight into the original design of punitive damages and tracks the Court’s increasing reliance on the punitive-to-compensatory ratio, beginning in the late 1980s. Part III will explain the flaws of the Court’s paradigm. In addition, Part III will outline an alternative approach to reviewing punitive damage awards that will both alleviate the Court’s constitutional concerns and remain true to the fundamental purposes underlying their imposition. . .