February 22, 2010

Barnes v. Morales: Punitive Damages Can Be Awarded for Purely Economic Harm

This unpublished opinion isn't exactly earth-shattering, but we mention it as part of our ongoing effort to catalog all of the California appellate opinions on punitive damages.

The defendant in this fraud case challenged a $56,000 punitive damages award, arguing that punitive damages could not be awarded in this case because the plaintiff's $295,000 compensatory damages award was purely economic. The Court of Appeal easily disposed of that argument, noting that Civil Code section 3294 expressly authorizes punitive damages for fraud and does not require an award of non-economic damages.