Asbestos is one of many products which have a once-latent danger now facing consumers. Our judicial system uses many means to confront these dangers, including imposing punitive damages on manufacturers. At what point does a manufacturer's business decisions affect society such that punitive damages become necessary? This issue is increasingly important in our highly industrialized and technological society. Angotti v. Celotex Corp. mandates an in-depth examination of this issue: first, how are jurisdictions other than Missouri approaching this problem; second, what considerations affect how punitive damages are used in a products liability setting; third, does Missouri's approach further these considerations; and finally, what will post- Celotex courts in Missouri require to support punitive damages? This Note addresses all of these questions.

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