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

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, 284 Cal.Rptr. 318, 813 P.2d 1348 ( 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, 284 Cal.Rptr. 318, 813 P.2d 1348.) Plaintiff has the burden of proof. ( Id. at p. 119, 284 Cal.Rptr. 318, 813 P.2d 1348.)

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, 284 Cal.Rptr. 318, 813 P.2d 1348 ["[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, 58 Cal.Rptr.3d 686, the court summarized the pertinent court of appeal authorities on the point: