Punitive damages in tort law are awarded for retribution and deterrence. The U.S. Supreme Court's decision in Phillip Morris USA v. Williams raised questions about the constitutionality of excessive punitive awards. The case involved a $79.5 million punitive award, much higher than compensatory damages, which may be unconstitutional. The Court has not addressed this issue in cases of serious injury or death, leading to new questions about how to justify such awards. By tying retribution to compensatory damages limitations, a method was developed to quantify punitive damages, justifying the$79.5 million award in Williams. This method ensures that punitive damages meet due process requirements and help courts determine if an award is excessive.