In what circumstances have punitive damages been awarded in dog bite cases?

Downing complains that the trial court asked whether punitive damages had been awarded in any dog bite case, claiming that this is irrelevant. We disagree. The complaint alleged strict liability under section 3342 and negligence, and punitive damages are "typically awarded for intentional torts" while "cases involving unintentional torts are far fewer." (Lackner v. North, supra, 135 Cal.App.4th at p. 1212.) We have found no case involving a dog bite where the court found the defendant's actions despicable for the purpose of awarding punitive damages; such a case would have provided a basis for comparison. (See id. at pp. 1212-1213.)