What is the test for determining whether a plaintiff is entitled to a punitive damages award?

As noted, under California law, a defendant's wealth is an important factor in determining whether a punitive damages award is excessive. (Corenbaum, supra, 215 Cal.App.4th at p. 1337.) " 'Even if an award is entirely reasonable in light of the other two [California law] factors . . . , the award can be so disproportionate to the defendant's ability to pay that the award is excessive for that reason alone." (Adams v. Murakami, supra, 54 Cal.3d at p. 111.) Absent meaningful evidence of a defendant's financial condition, a reviewing court cannot determine whether a punitive damages award is

Page 16