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(collectively Liggett)

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39 Given the enormity of the punitive damage award rendered by the Phase I jury, however, the Engle III court held due process demands that a review of the punitive damages award include[] an evaluation of the punitive and compensatory amounts awarded to ensure a reasonable relationship [exists] between the two. 40 the court concluded that in the absence of a compensatory award, or where, as in this instance, the jury had awarded class-wide punitive damages before a finding of liability and compensatory damages, a reviewing court could not make this determination

"I don't believe minors should have access to it, said e-cigarette user from Portland Steven Willey

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