As far as the determination of the quantum of these punitive damage awards is concerned, the proper approach is to focus on the defendant’s misconduct and not the plaintiff’s loss. A formulaic approach, such as imposing a fixed ratio between compensatory and punitive damages, does not permit a consideration of the many variables necessary to reach a fair award. The facts of each case should be related to the underlying purposes of punitive damages. The quantum of the damages should be the lowest award that will serve those purposes. Proportionality is the governing rule for quantum. See Whiten v. Pilot Insurance Co., supra at paras. 71-74.
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