The Violent Crime and Law Enforcement Act of 1994

The Court further stated in its opinion:
[I]t is contended that the fines imposed are so excessive as to constitute a taking of the
defendant's property without due process of law. It is not contended in this connection
that the prohibition of the Eighth Amendment to the federal Constitution against
excessive fines operates to control the legislation of the states. The fixing of punishment
for crime or penalties for unlawful acts against its laws is within the police power of the
state. We can only interfere with such legislation and judicial action of the states
enforcing it if the fines imposed are so grossly excessive as to amount to a deprivation of
property without due process of law.
In essence, the government must not be able to confiscate such a large amount of
property without following an established set of rules created by the legislature.
Browning-Ferris v. Kelco
In Browning-Ferris Industries of Vermont, Inc. v. Kelco Disposal, Inc., 492 U.S. 257
(1989), the Supreme Court ruled that the Excessive Fines Clause does not apply "when
the government neither has prosecuted the action nor has any right to receive a share
of the damages awarded".
While punitive damages in civil cases are not covered by the Excessive Fines Clause,
such damages were held to be covered by the Due Process Clause of the Fourteenth
Amendment, notably in State Farm Mutual Automobile Insurance Co. v. Campbell, 538
U.S. 408 (2003).
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