In a products liability action, Honda was found liable for injuries received by the plaintiff in an ATV accident. Honda was liable for a $5 million punitive damage award, and both the state appellate court and the Oregon Supreme Court declined to review the award for excessiveness based on an amendment to the Oregon constitution. The Supreme Court of United States held that the amendment to the Oregon constitution violated due process. The Court held that judicial review of punitive damage awards for excessiveness was a long-standing common law tradition that was critical in protecting against arbitrary deprivations of property, and that Oregon had not instituted a substitute procedure to maintain these protections.[2]