Background
After drinking six beers in 90 minutes at a work event, Collin Reeves drove through a red light and struck a car driven by 20-year-old Audrianne Dillard, killing her, her passenger Jesel Morales, and their dog. Testing showed Reeves had a blood-alcohol concentration of 0.145 shortly after the crash. He later pleaded guilty to felony endangerment.
The victims’ parents sued Reeves for wrongful death. A jury awarded each of the three plaintiffs $8 million in compensatory damages and $22 million in punitive damages, while assigning 88% of the fault to Reeves and 12% to Audrianne. After applying comparative fault, the superior court entered a total judgment of $79.2 million. It later credited Reeves with $1.2 million in advance payments but otherwise denied his motion for a new trial or remittitur.
The Court’s Holding
The Arizona Court of Appeals affirmed. It held that the punitive awards, reflecting a 2.75-to-1 ratio of punitive to compensatory damages after comparative-fault reductions, did not violate due process. Reeves’s conduct ranked toward the higher end of reprehensibility because it caused deaths, showed reckless disregard for others’ safety, and followed more than a decade of repeated drunk driving despite his knowledge of the danger.
The court also found no abuse of discretion in the superior court’s refusal to reduce the damages based on verdicts in other cases, which were only marginally relevant. The record did not show that passion or prejudice produced a verdict so unfair, unreasonable, and outrageous that it shocked the conscience. Nor was the superior court required to consider Reeves’s post-trial net-worth exhibit: he had not disclosed financial information before trial and had expressly withdrawn any poverty defense.
Reeves waived two other sets of arguments. At oral argument he withdrew his challenges to the sufficiency of the evidence supporting an “evil mind” and causation, and he failed at trial to object to the closing-argument comments he later characterized as misconduct.
Key Takeaways
- Substantial compensatory damages do not create an automatic 1-to-1 constitutional ceiling on punitive damages; the permissible ratio depends on the facts and the degree of reprehensibility.
- A repeated pattern of drunk driving, undertaken with knowledge of its risks and culminating in two deaths, supported the 2.75-to-1 punitive-to-compensatory ratio.
- A defendant who neither timely discloses financial evidence nor preserves objections at trial may be unable to obtain appellate relief based on those issues.
Why It Matters
The decision illustrates how Arizona courts apply the federal punitive-damages guideposts in a wrongful-death case involving highly reprehensible conduct. It also reinforces the broad role of juries in valuing noneconomic loss and the limited significance of verdict comparisons when reviewing damages.
The memorandum decision is not precedential under Arizona Supreme Court Rule 111(c), but it offers practical guidance on preserving objections, presenting financial-condition evidence, and framing due-process challenges to punitive awards.