Few decisions of the past quarter century are as likely to alter the way in which civil litigation is conducted as much as State Farm Mutual Automobile Insurance Company v. Inez Preece Campbell, 123 S. Ct. 1513 (April 7, 2003). In Campbell, the U.S. Supreme Court, for the third time in the past seven years, reined in the use of punitive damages as an all-too-often arbitrary and capricious substitute for criminal penalties. The Court reiterated that defendants--even those who behave very badly--have a constitutionally protected right to have a civil law "punishment" assessed accord