November 25, 2014

Another punitive damages award reversed due to insufficient financial condition evidence (Wilson v. Autler)

This unpublished opinion is the latest example of the California Court of Appeal vacating a punitive damages award because the plaintiff failed to present meaningful evidence of the defendant's financial condition. 

The defendant testified that she owned a home and paid cash for it.  But the Court of Appeal (Fourth District, Division Two) said that evidence was not nearly sufficient to support a punitive damages award; the plaintiff presented no evidence of the value of the house, the defendant's other assets or liabilities, or her income and expenses.  As a result, the court vacated $50,000 in punitive damages.