What is the test for punitive damages in a medical malpractice case?

"Because punitive damages are imposed 'for the sake of example and by way of punishing the defendant' [citation], they are typically awarded for intentional torts such as . . . intentional infliction of emotional distress . . . . [Citation.] . . . [] On the other hand, cases involving unintentional torts are far fewer and the courts have had to consider various factors in determining whether the defendant's conduct was despicable. Thus, punitive damage awards have been reversed where the defendant's conduct was merely in bad faith and overzealous." (Lackner v. North (2006) 135 Cal.App.4th 1188, 1212.)