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gauging the "reprehensibility" of the defendant's <br />actions. Id. at 357 ( "[W]e recognize that conduct <br />that risks harm to many is likely more reprehensible <br />than conduct that risks harm to only a few. And a <br />jury consequently may take this fact into account in <br />determining reprehensibility. "). This holding built <br />upon the Court's prior decision in State Farm which <br />directed trial courts to consider whether the <br />defendant's conduct evinced "reckless disregard of <br />the health or safety of others" when assessing the <br />reprehensibility of a defendant. 538 U.S. at 419. <br />Here, the statute cabins the jury's consideration of <br />a defendant's disregard for "the rights and safety <br />of others" to the narrow task of gauging "willful <br />and wanton conduct." See §13- 21- 102(1)(b). By <br />listing harm to nonparties as a factor in assessing <br />reprehensibility, the statute complies with the due <br />process limitations <br />on exemplary <br />damages <br />set forth <br />in both Philip <br />Morris and <br />State <br />Farm. See <br />e.g., Grefer v. Alpha Technical,965 So.2d 511, 517 <br />(La. App. 4th Cir. 2007) . Thus, because the statute <br />permits a jury to consider harm to nonparties only <br />for the purpose of assessing whether the defendant's <br />