The Supreme Court of Pennsylvania has held that punitive damages do not have to bear a reasonable relationship to compensatory damages.
Kirkbride v. Lisbon Contractors, Inc., 521 Pa. 97, 555 A.2d 800 (1989).
Thomas H. Ayoob,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol28/iss4/16