Footnote 131

See, e.g., Tresa Baldas, Verdicts Swelling from Big to Bigger: Jurors Desensitized, or Just Plain Angry, Nat'l L.J., Nov. 25, 2002, at A1 (discussing recent huge verdicts, two of which exceeded $3 billion); Gibbs, supra note 114, at 237 (noting that large verdicts against employers are becoming increasingly common); Adam Liptak, Pain-and-Suffering Awards Let Juries Avoid New Limits, N.Y. Times, Oct. 28, 2002, at A14 (reporting affirmance of $20 million pain-and-suffering award for plaintiff in Gilbert v. Daimler Chrysler Corp., No. 227392, 2002 Mich. App. LEXIS 1168 (Mich. Ct. App. July 30, 2002), appeal granted, SC: 122457, 2003 Mich. LEXIS 718 (Mich. Apr. 8, 2003)).