On what basis can a jury award punitive damages for failing to comply with the provisions of section 3294 of the Civil Code?

On the other hand the trial court, in an attempt to construe the federal statute's distinction between a willful failure to comply, and a negligent failure to comply with the provisions of the act, may have been drawing an analogy from California law between cases of ordinary negligence where no punitive damages are recoverable (see Gombos v. Ashe (1958) 158 Cal.App.2d 517, 526-530, 322 P.2d 933) and the cases under Civil Code section 3294 where the defendant has been guilty of such oppression, fraud or malice, express or implied, as will justify punitive damages. In the latter case he was attempting to construe federal law. The propriety of that interpretation is reviewed below. (Part III, infra.)