The Sixth Circuit today ordered a district court to cut a jury’s punitive damages award to achieve a one-to-one ratio to the compensatory damages. The jury awarded an elderly widow $400,000 in actuals plus $2,628,600 in punitives against a bank for violating the Fair Credit Reporting Act. The district court, after an initial appeal and remand, ordered reduction of the $2,628,600 to $2,228,600. The Sixth Circuit held the subtraction of $400,000 not enough to fix the unconstitutional overkill of the punitive element. And it directed the district court to slash the award to no more than $400,000 — the same as actual damages. Bach v. First Union Nat’l Bank, No. 06-3660 (6th Cir. May 15, 2007).