Icicle Seafoods, Inc. v. Clausen

(1) Whether, in determining the ratio between compensatory and punitive damages for purposes of applying federal limits on punitive damages, court-awarded attorney"s fees are properly included as compensatory damages; and (2) whether, and to what extent, punitive damages in maritime cases may exceed the 1:1 ratio between compensatory and punitive damages applied by the Court"s Exxon Shipping Co. v. Baker decision.