California, United States of America
The following excerpt is from Downey Savings & Loan Assn. v. Ohio Casualty Ins. Co., 189 Cal.App.3d 1072, 234 Cal.Rptr. 835 (Cal. App. 1987):
Ohio also contends the punitive damage award was imposed in a civil action " 'unaccompanied by the types of safeguards present in criminal proceedings,' " in violation of the Fourteenth Amendment due process clause. Where, as here, the action is civil in nature, civil rules rather than criminal rules of procedure apply. (Toole v. Richardson-Merrell Inc. (1967) 251 Cal.App.2d 689, 717, 60 Cal.Rptr. 398.) Besides, Ohio has failed to identify the "safeguards"
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