What is the test for determining whether a punitive award is unconstitutionally excessive?

on remand. Under the principles discussed above, the trial court must adjust the punitive award accordingly to maintain the approximate one-to-one ratio. (See Nickerson v. Stonebridge Life Ins. Co. (2016) 63 Cal.4th 363, 368, 203 Cal.Rptr.3d 23, 371 P.3d 242 ["In determining whether a punitive damages award is unconstitutionally excessive, Brandt fees may be included in the calculation of the ratio of punitive to compensatory damages, regardless of whether the fees are awarded by the trier of fact as part of its verdict or are determined by the trial court after the verdict has been rendered."].)