The following excerpt is from In Re : The Exxon Valdez v. Hazelwood, 270 F.3d 1215 (9th Cir. 2001):
102. 139 F.3d 1241, 1248 (9th Cir. 1998); see also Barnes v. Logan, 122 F.3d 820, 823-24 (9th Cir. 1997) (considering first if the punitive damages award was in manifest disregard of the law, then considering whether the award violated due process).
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