Claims for punitive damages in environmental tort cases raise a number of interesting state-law and constitutional issues. Recently, the U.S. Court of Appeals for the Eleventh Circuit had the occasion to address some of these issues in Johansen v. Combustion Engineering, Inc.¹ This Dialogue discusses the aspects of the Johansen decision that have particular relevance in environmental cases and seeks to provide practitioners with some guidance as to how to approach these issues in future cases.²