California, United States of America
The following excerpt is from Sinclair v. Katakis, F058822 (Cal. App. 2013):
Plaintiffs cite Bardis v. Oates (2004) 119 Cal.App.4th 1 (Bardis) as analogous case law that compels reversal. We disagree. In Bardis, the plaintiff partners sued the managing partner of a real estate partnership for fraud, and breach of contract and tort duties based on allegations of self-dealing, secret markups, and clandestine commissions. The jury awarded the plaintiffs compensatory and punitive damages. The defendant challenged the judgment, claiming the plaintiffs failed to show they were damaged and the punitive damages were excessive under recent case law. (Id. at p. 5.) The appellate court affirmed the compensatory damage award and modified the punitive damage award to comply with the single digit guidepost set by recent case law. (Id. at pp. 16, 25-26.)
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