While attempting to pass several cars on a two-lane road, Campbell drove into oncoming traffic. An innocent driver swerved to avoid Campbell and died in a collision with a third driver. The family of the deceased driver and the surviving third driver both sued Campbell. 

As Campbell’s insurer, State Farm represented him in the lawsuit. It turned down an offer to settle the case for $50,000, the limit of Campbell's policy. The company had nothing to gain by settling because even if Campbell lost big at trial State Farm’s liability was capped at $50,000. 

A jury returned a judgment against Campbell for $185,000. He was responsible for the $135,000 that exceeded his policy limit. He argued with State Farm, claiming that it should have settled the case. Eventually, State Farm paid the entire $185,000, but Campbell still sued the company, alleging fraud and intentional infliction of emotional distress.

His lawyers presented evidence that State Farm had deliberately acted in its own best interests rather than his. The jury was convinced, and in the end, Campbell won an award of $1 million in compensatory damages, and $145 million in punitive damages. State Farm appealed.

Questions:

1. What is the limit on punitive damages?

2. Did State Farm shoe any evil intent in turning down the offer to settle? 

3. What would have been an appropriate punitive damage award?