Ind. Code § 34-51-3-4

Section 34-51-3-4 caps a punitive-damages award at the greater of three times the compensatory damages or $50,000, and that cap is constitutional under Indiana's jury-trial and separation-of-powers provisions.

State of Indiana v. Doe · filed 2013-05-14

The cap is a public policy judgment that punitive damages in civil cases should not exceed a certain amount. ... Just so here; the legislative branch imposed a cap on the amount of punitive damages that a jury may award, and it provided that 75% of those damages would be allocated to the VCF. The trial court had absolute discretion to award damages as it saw fit—provided the award fit within those statutory parameters. Article 3, Section 1 of our Constitution demands nothing more. ... We hold that Indiana Code §§ 34-51-3-4, -5, and -6 do not violate either Article 1, Section 20 or Article 3, Section 1 of our Indiana Constitution.

Section 34-51-3-4 caps punitive-damage awards at the greater of three times compensatory damages or $50,000, but that cap does not apply to statutory treble damages under the Sales Representative Act.

Andrews v. Mor/Ryde International, Inc. · filed 2014-06-19

And it used three mechanisms to accomplish those objectives: requiring proof by “clear and convincing evidence,” I.C. § 34-51-3-2 (2008); capping awards at the greater of three times compensatory damages or $50,000, I.C. § 34-51-3-4; and diverting three-fourths of the punitive damage award to the State, I.C. § 34-51-3-6. ... We therefore grant transfer, hold that treble damages under the Sales Representative Act are not subject to the Punitive Damages Act, and accordingly reverse the trial court.

Section 34-51-3-4 caps punitive damages at three times the compensatory damages awarded on the claim or claims for which punitive damages were pleaded or tried by consent, rather than on unrelated claims.

Techna-Fit, Inc. and Stuart Trotter v. Fluid Transfer Products, Inc. · filed 2015-10-14

We interpret “the amount of compensatory damages awarded in the action” under Indiana Code Section 34-51-3-4 to mean the amount of compensatory damages awarded for the claim or claims for which punitive damages were requested in a party’s pleadings or, if not requested in the pleadings, tried by consent. ... But because FTP is only entitled to punitive damages for the breach of fiduciary duty, it follows that only those compensatory damages which are the predicate for the punitive damages claim can be used to calculate the statutory cap. ... We hold that FTP is not entitled to punitive damages on its breach of contract claims and that the punitive damages award is limited to three times the compensatory damages awarded for Trotter’s breach of fiduciary duty. I.C. § 34-51-3-4.

Section 34-51-3-4 caps each individual punitive-damage award at three times the compensatory damages awarded for the claim or claims supporting punitive damages, rather than capping the aggregate awards against multiple defendants.

Indiana GRQ, LLC v. American Guarantee and Liability Insurance Company · filed 2023-06-20

The answer: individually. The statute speaks in terms of “[a] punitive damage award.” Ind. Code § 34-51-3-4. It speaks of an individual and single punitive damage award. ... A punitive damage award may not be more than three times “the amount of compensatory damages awarded in the action.” Ind. Code. § 34-51-3-4. No matter the reference to “the action,” Indiana law reads this statute as meaning “the amount of compensatory damages awarded for the claim or claims for which punitive damages were requested in a party’s pleadings or, if not requested in the pleadings, tried by consent.” Techna-Fit, Inc. v. Fluid Transfer Prods., 45 N.E.3d 399, 414-416 (Ind. Ct. App. 2015).

Section 34-51-3-4 caps punitive damages at the greater of three times the compensatory damages awarded or $50,000.

PULLINS v. UNITED PARCEL SERVICE INC. · filed 2024-12-19

However, punitive damages are capped at the greater of "(1) three (3) times the amount of compensatory damages awarded in the action; or (2) fifty thousand dollars ($50,000)." Ind. Code § 34-51-3-4. Here, because of Indiana's punitive damages cap, it is legally certain that Mr. Pullins cannot meet the requisite jurisdictional amount of $75,000. Three times his compensatory damages allegation would be $45,000, so $50,000 would be the greater of the two and would be the applicable capped punitive damages amount under Indiana law.

Section 34-51-3-4 caps punitive damages at the greater of three times the compensatory damages or $50,000.

Stroud v. Lints · filed 2002-01-16

Our legislature has enacted a cap on punitive damages, so that they cannot exceed three times the compensatory damages or $50,000, whichever is greater. Ind.Code § 34-51-3-4. What that means in the present case is that once it was established by clear and convincing evidence that punitive damages against Stroud were appropriate, the range of such damages was established by statute as being between $1 and approximately $4.1 million, or three times the compensatory damages of $1,381,500.

The punitive damages cap applies to each individual award without reducing compensatory damages to an insurer’s contractual pro rata share.

Indiana GRQ, LLC v. American Guarantee and Liability Insurance Company · filed 2024-03-22

The court also observes that its ruling on the punitive damages cap already accounts for its ruling today—in short, each punitive damage award is well within the punitive damages cap even viewing the compensatory damages on the bad faith claim to be only the environmental award [ECF 239 at 5-6].

Section 34-51-3-4 does not apply retroactively to a case filed before its enactment when the legislature did not expressly direct retroactive application.

Fall v. Indiana University Board of Trustees · filed 1998-12-30

Therefore, we shall not retroactively apply Ind.Code § 34-51-3-4 to this case.