July 5, 2009

Clark v. Clark: $2.5 Million Net Worth Sufficient to Support $100,000 Punitive Damages Award

We've been blogging recently about the slew of cases reversing punitive damages awards because the plaintiff failed to present meaningful evidence of the defendant's financial condition.

Here's a change: in an unpublished opinion, the California Court of Appeal (First Appellate District, Division Three), reverses a trial court's determination that the plaintiff's evidence of the defendant's financial condition was insufficient. The Court of Appeal concluded the evidence established a net worth of $2.5 million, more than enough to support a $100,000 award. The Court of Appeal faulted the trial court improperly weighing evidence and considering evidence not before the jury.