Can an employer be held liable for punitive damages based upon the acts of its employees?

An employer "may not be held liable for punitive damages based upon the acts of its employees unless the employer (1) 'had advance knowledge of the unfitness of the employee and employed him or her with a conscious disregard of the rights or safety of others,' (2) 'authorized or ratified the wrongful conduct for which the damages are awarded,' or (3) 'was personally guilty of oppression, fraud, or malice.'" Rosas v. Chipotle Mexican Grill, Inc., CASE No. SACV 12-2189-JLS(RNBx), 2014 WL 12637412, at *3 (C.D. Cal. July 22, 2014) (quoting Cal. Civil Code 3294(b)). As to a corporate employer, "the advance knowledge and conscious disregard, authorization, ratification or act of oppression, fraud, or malice must be on the part of an officer,

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