This article predicted that one of the most important issues in future tort litigation would be the role of the Due Process Clause of the Fourteenth Amendment in constraining the imposition of punitive damages by state court juries. In Pacific Mutual Life Insurance Co. v. Haslip, the Supreme Court found that the Due Process Clause of the Fourteenth Amendment limits, but does not prohibit, the imposition of punitive damages. The article argues that procedural due process would be protected by giving the jury adequate guidance on the nature and purpose of punitive damages, by using post-verdict judicial review to assure that the award is reasonable, and by applying the proper standard of proof. it also reasoned that substantive due process would be served by rendering an award of punitive damages neither excessive in degree (as compared with the award for compensatory damages) nor in frequency (as when a single course of tortious conduct results in the multiple imposition of punitive damages).