 v. Campbell" (2003), the Court held that punitive damages might only be based on the acts of the defendants which harmed the plaintiffs.The Court also elaborated on the factors courts must apply when reviewing a punitive award under due process principles.Most recently, in "Philip Morris USA v. Williams" (2007), the Court ruled that punitive damage awards cannot be imposed for the direct harm that the misconduct caused others, but may consider harm to others as a function of determining how reprehensible it was.