Hadelman v. DeLuca

Summary

The Connecticut Supreme Court affirmed confirmation of an arbitration award granting the plaintiffs $300,000 in punitive damages but no compensatory damages. The court held that Connecticut has no well-defined public policy against excessive punitive damages awards and that the federal due process analysis from BMW of North America, Inc. v. Gore does not apply to an arbitration award absent state action.

Holdings

1. Connecticut does not have a well-defined public policy against an award of excessive punitive damages; therefore, de novo review did not justify vacating or refusing to confirm this arbitration award.
2. The due process limitations discussed in BMW of North America, Inc. v. Gore do not apply to an arbitration award because the award does not constitute state action and is not converted into state action by judicial confirmation.

Questions Presented

1. Whether the arbitration award of punitive damages was excessive and violated Connecticut's public policy.
2. Whether the punitive damages award violated federal due process under BMW of North America, Inc. v. Gore.

Disposition

affirmed