What is the test for determining whether a defendant's financial condition is sufficient to sustain an award of punitive damages?

Evidence of the defendant's financial condition is a prerequisite for an award of punitive damages. (Adams v. Murakami (1991) 54 Cal.3d 105, 108-109 (Adams) ["an award of punitive damages cannot be sustained on appeal unless the trial record contains meaningful evidence of the defendant's financial condition"].) "Without such evidence, a reviewing court can only speculate as to whether the award is appropriate or excessive." (Id. at p. 112.) Plaintiff has the burden of proof. (Id. at p. 119.)

Adams "decline[d]... to prescribe any rigid standard for measuring a defendant's ability to pay." (Adams, supra, 54 Cal.3d at p. 116, fn. 7 ["[w]e cannot conclude on the record before us that any particular measure of ability to pay is superior to all others or that a single standard is appropriate in all cases"].) In Baxter v. Peterson (2007) 150 Cal.App.4th 673, the court summarized the pertinent court of appeal authorities on the point:

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