Browning-Ferris Industries of Vermont, Inc. v. Kelco Disposal, Inc.

Browning-Ferris Industries v. Kelco Disposal, 492 U.S. 257 (1989), was a case in which the Supreme Court of the United States held that the Eighth Amendment's prohibition of unreasonable fines does not apply to punitive-damage awards in civil cases when the United States is not a party.

Joseph Kelley was a district manager for BFI until 1980, when he left to found his own company, Kelco Disposal.

Kelco also claimed, as an alternative state-law cause of action, that BFI interfered with its contracts with its customers.

The Second Circuit affirmed the trial court's decision on both liability and damages, finding for the sake of argument that the jury's punitive-damage award was not excessive whether or not the Eighth Amendment applied to this case.

The Supreme Court granted certiorari to consider the specific question of whether the excessive fines clause applies to civil cases involving purely private parties.