How is a defendant's net worth determined in determining damages?

The Adams court did not prescribe a rigid standard for measuring a defendant's ability to pay punitive damages, and stated it could not conclude, based on the record before it, "that any particular measure of ability to pay is superior to all others or that a single standard is appropriate in all cases." (Adams, supra, 54 Cal.3d at p. 116, fn. 7.) Net worth is often described as "the critical determinant of financial condition"; however, "there is no rigid formula and other factors may be dispositive especially when net worth is manipulated and fails to reflect actual wealth." (County of San Bernardino v. Walsh (2007) 158 Cal.App.4th 533, 546.)