The proper limitations on a punitive damage award depend on the conception of punitive damages. Is the award a private law remedy, limited to resolving the dispute between the parties? Or is it a public law remedy, capable of addressing public harm and achieving public good? The Supreme Court has not wavered from public law ideas of punitive damages—that the damages serve the state’s interests and are similar to criminal punishments. At the same time, the Court’s holdings also indicate a private law idea by focusing on the actual injury to the plaintiff. This focus included prohibiting punitive damages from punishing the defendant for causing harm to nonparties.