Webb v. CSX Transportation involved a fatality at a Pelzer, South Carolina, railroad crossing. The jury awarded Plaintiff $3 million actual damages in his wrongful death action; $250,000 actual damages in the survival action; and $875,000 punitive damages.
A key issue on appeal was the emphasis in Plaintiff's closing argument of CSX's failure to repair a bridge. Earlier in the case the trial judge held that the failure to repair was not the proximate cause of the accident. The Supreme Court found that such a closing argument was unduly prejudicial:
The trial judge's ultimate correct conclusion that the failure to replace the bridge was not a proximate cause of the accident renders all this evidence and argument irrelevant, to the extreme prejudice of CSX. We hold that these circumstances require a new trial absolute.
The Court also offered this on the punitive damages issue:
It is clear that much of the evidence of acts in other jurisdictions, including CSX and other railroads, and of acts unrelated to crossing safety in South Carolina admitted in this trial is not constitutionally permissible under Campbell [State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003)] . We reverse the punitive damage award and instruct that on retrial, evidence sought to be admitted on the issue of punitive damages should be closely scrutinized for its relationship to the particular harm suffered by the Plaintiff.
This instruction on punitive damages is yet more evidence that the Court is very seriouss that evidence on the issue of punitive damages must directly relate to the harm suffered by the Plaintiff.