The district court did not err in reducing punitive damages against Monsanto for failure to warn of cancer risks from Roundup to a ratio of 3.8 to 1 to actual damages, though that ratio was on the borderline of being excessive.  The harm caused was physical, yet the jury awarded plaintiff $5 million in actual damages, 96% of which was noneconomic damages.  Monsanto ignored safety risks.  It conducted no studies of Roundup’s potential carcinogenic quality though notified that there was reason to suspect it.  Plaintiff was financially vulnerable.  Monsanto repeatedly sold Roundup on a broad scale.