California, United States of America
The following excerpt is from Jackson v. Johnson, 5 Cal.App.4th 1350, 7 Cal.Rptr.2d 482 (Cal. App. 1992):
The jury having determined that one of the elements of malpractice, actual damages, had not been established, the punitive damages award is invalid.
c. Clark v. McClurg and its progeny
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.