Until 1996, punitive damages represented more of a risk factor inherent in litigation, rather than an opportunity to control risk factors, for small business owners. Specifically, during the 20-year period leading up to 1996, business owners suffered extremely large punitive damages awards. These awards, in many cases involving larger businesses, amounted to tens of millions of dollars, and some awards exceeded $100 million dollars. In 1996, however, the U.S. Supreme Court established guidelines for punitive damages awards that have significantly reduced the size of awards since that time.