Lawnwood Medical Center, Inc. v. Sadow

Issue: (1) Whether punitive damages for intentional harm are exempt from the Court's guidepost analysis to determine whether an award of punitive damages is unconstitutionally excessive; (2) whether state law can exempt punitive awards for certain conduct from the guidepost analysis mandated by the Constitution; and (3) whether a court may rely on the defendant's wealth - rather than awards in similar cases or comparable legislative penalties - as an objective indicator of the constitutionality of a punitive award when actual damages are small or nominal.