In State Farm Mutual V

In State Farm Mutual v. Campbell, the court laid out a three-part analysis for determining the constitutionality of a statute regulating punitive damages. Which of the following is not one of the three criteria specified by the court?

A) the degree of reprehensibility of the defendant's misconduct
B) the disparity between the actual or potential harm suffered by the plaintiff and the punitive-damage award
C) whether the harm resulted from a criminal act or a civil act
D) the difference between the punitive damages awarded and the civil penalties authorized or imposed in similar or comparable cases