What is the current state of the law on net worth of a plaintiff in a motor vehicle accident case?

In Kenly v. Ukegawa (1993) 16 Cal. App.4th 49, 57, 19 Cal.Rptr.2d 771, this court held "that in most cases there must be evidence of the defendant's net worth to support the punitive damage award." We explained that in examining assets without examining liabilities, or without "evidence of the entire financial picture," there was a risk of "crippling or destroying the defendant." (Ibid.) We further noted we could surmise the defendants had millions in assets, but we could also assume their debts were equally high. "Without evidence of the actual total financial status of the defendants, it is impossible to say that any specific award of punitive damage is appropriate." (Id. at p. 58, 19 Cal.Rptr.2d 771.)

In Lara v. Cadag (1993) 13 Cal.App.4th 1061, 1065, footnote 3, 16 Cal.Rptr.2d 811, the court concluded that "`[n]et worth' is subject to easy manipulation and, in our view, it should not be the only permissible standard. Indeed, it is likely that blind adherence to any one standard could sometimes result in awards which neither deter nor punish or which deter or punish too much." The court there found that a consideration of income alone does not permit meaningful review and "something more is required." (Ibid.)