Shell Oil Co. v. Hebble

1) Whether, in calculating the ratio of punitive damages to harm to a plaintiff, heightened penalties such as 12% interest imposed to compel compliance may be treated as “compensatory”?; 2) Whether, in determining the maximum punitive damages award in a case involving a substantial compensatory award and only economic harm, courts should be guided by the 1-to-1 ratio mentioned in State Farm Mutual Insurance Co. v. Campbell or instead presume that anything within the range of 4-to-1 is permissible.