Bankers Life & Casualty Co. v. Crenshaw

486 U.S. 71 (1988)

Facts

Crenshaw's (P) foot was injured by a car alternator falling on it while at home. P tried home treatment, but the injury became severe over time, and eventually, it required amputation. P had a $20,000 insurance policy for loss of limb due to accidental bodily injury and P submitted a claim. D denied the claim under the reason that the amputation was due to a preexisting condition of arteriosclerosis. P offered statements refuting that conclusion by three doctors who had treated him who diagnosed the problem as one of gangrenous necrosis. P eventually sued in court for $20,000 in actual and $1,635,000 in punitive damages for bad faith because D knew its files on the matter were incomplete as it did not have the hospital reports and D did nothing as required under law to correct that matter. The jury gave P the verdict for $20,000 and $1.6 million in punitives. The Mississippi Supreme Court affirmed. On appeal, D did not raise a federal constitutional issue of the size of the punitive damages award. The Supreme Court granted certiorari.